United States v. Marlon Eason, et al. (11th Cir. March 2020)
ACCA, Career Offender, Eleventh Circuit, Sentencing
|Joining several other circuits, the Eleventh Circuit held that a conviction for Hobbs Act robbery does not qualify as a “crime of violence” for the sentencing enhancement under either the elements clause of U.S.S.G. ยง 4B1.2(a) or as an enumerated robbery or extortion offense, as a defendant can be convicted of Hobbs Act robbery based merely on a threat to property.