Commerce Clause Broad Interpretation in Taylor v United States
In Taylor v United States (2016), the U.S. Supreme Court held that “commerce” under the Hobbs Act should be interpreted broadly. Accordingly, it found that the government had satisfied its burden by establishing that the defendant robbed a drug dealer of drugs or drug proceeds.
The Facts in Taylor v United States
Anthony Taylor was indicted under the Hobbs Act on two counts of affecting commerce or attempting to do so through robbery for his participation in two home invasions targeting marijuana dealers. In both cases, Taylor and other gang members broke into the homes, confronted the residents, demanded the location of drugs and money, found neither, and left relatively empty handed.
The Hobbs Act makes it a crime for a person to affect commerce, or to attempt to do so, by robbery. The Act defines “commerce” broadly as interstate commerce “and all other commerce over which the United States has jurisdiction.”
During Taylor’s trial, the prosecution sought to preclude him from offering evidence that the drug dealers he targeted dealt only in locally-grown marijuana. The trial court excluded that evidence, and Taylor was convicted on both counts. The Fourth Circuit affirmed, holding that, given the aggregate effect of drug dealing on interstate commerce, the Government needed only to prove that Taylor robbed or attempted to rob a drug dealer of drugs or drug proceeds to satisfy the commerce element.
The Court’s Decision in Taylor v United States
By a vote of 7-1, the Court held that the Hobbs Act applies to drug robbery. As Justice Samuel Alito, Jr. wrote for the majority, “prosecution in a Hobbs Act robbery case satisfies the Act’s commerce element if it shows that the defendant robbed or attempted to rob a drug dealer of drugs or drug proceeds.”
In his opinion, Justice Alito highlighted that the Commerce Clause authorizes Congress to regulate activities that have a substantial aggregate effect on interstate commerce, which includes “purely local activities that are part of an economic ‘class of activities’ that have a substantial effect on interstate commerce.” He also specifically noted that “the Commerce Clause gives Congress authority to regulate the national market for marijuana, including the authority to proscribe the purely intrastate production, possession, and sale of this controlled substance.”
As Justice Alito further reasoned:
Because Congress may regulate these intrastate activities based on their aggregate effect on interstate commerce, it follows that Congress may also regulate intrastate drug theft. And since the Hobbs Act criminalizes robberies and attempted robberies that affect any commerce “over which the United States has jurisdiction,” §1951(b)(3), the prosecution in a Hobbs Act robbery case satisfies the Act’s commerce element if it shows that the defendant robbed or attempted to rob a drug dealer of drugs or drug proceeds. By targeting a drug dealer in this way, a robber necessarily affects or attempts to affect commerce over which the United States has jurisdiction.
The Dissent in Taylor v United States
Justice Clarence Thomas disagreed with the majority. He would “hold that the Act punishes a robbery only when the Government proves that the robbery itself affected interstate commerce.”
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Congress of the United States begun and held at the City of New-York, on Wednesday the fourth of March, one thousand seven hundred and eighty nine.
THE Conventions of a number of the States, having at the time of their adopting the Constitution, expressed a desire, in order to prevent misconstruction or abuse of its powers, that further declaratory and restrictive clauses should be added: And as extending the ground of public confidence in the Government, will best ensure the beneficent ends of its institution.