United States of America v. Chappelle, No. 20-3835 (2d Cir. 2022)
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Defendant was convicted of conspiracy to commit Hobbs Act robbery. Application Note 1 to Section 4B1.2 provides that, among other things, a conspiracy to commit a crime of violence is itself a crime of violence. The district court held that it was not obligated to defer to Application Note 1 because it was inconsistent with 4B1.2(a). The Government appealed.
The Second Circuit affirmed the district court’s ruling. The court held that the Hobbs Act robbery is not categorically a “crime of violence” under the career offender provision of the United States Sentencing Guidelines. The court explained that Hobbs Act robbery can be committed based solely on violence against property, whereas a “crime of violence” under Section 4B1.2 must be based on violence against people.
Here, the court explained it need not rule upon the validity of Application Note 1 in this context because the object of Defendant’s conspiracy offense (Hobbs Act robbery) was not a crime of violence as defined by Section 4B1.2. And if the object of the conspiracy is not a crime of violence, then the conspiracy itself cannot be one either (at least, not by virtue of Application Note 1).
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