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Statutory Interpretation – Hobbs Act

7th Circuit Court of Appeals

Case Name: United States of America v. Andrew McHaney

Case No.: 20-1690

Officials: ROVNER, HAMILTON, and SCUDDER, Circuit Judges.

Focus: Statutory Interpretation – Hobbs Act

Andrew McHaney is not the first defendant to try to persuade this court that Hobbs Act robbery is not a crime of violence as defined under 18 U.S.C. § 924(c). And despite our growing, unequivocal precedent to the contrary, we suspect he will not be the last, as defendants who are subject to the § 924(c) enhancement face significantly increased sentences. Unless the Supreme Court instructs otherwise, however, these attempts will be in vain. This court has declared several times that Hobbs Act robbery meets the definition of a crime of violence under 18 U.S.C. § 924(c) and thus is a qualifying predicate crime under the statute. We see no cause to alter that precedent.


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Derek A Hawkins is Corporate Counsel, at Salesforce.

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