United States v. Crawley, No. 19-7369 (4th Cir. 2021)
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In 2007, Crawley and two codefendants invaded a home and attacked and robbed a man they believed to be a drug dealer. A woman and two children were also in the home. Crawley pleaded guilty to conspiracy to commit Hobbs Act robbery, 18 U.S.C. 1951 and using, carrying, and brandishing firearms during and in relation to a crime of violence and a drug trafficking crime, 18 U.S.C. 924(c). Other counts were dismissed, including for attempting to possess with intent to distribute a Schedule II Controlled Substance, 21 U.S.C. 846. The court sentenced Crawley to 150 months on Count One and 84 months on Count Three, to run consecutively. Crawley later unsuccessfully moved to vacate his sentence under 28 U.S.C. 2255.
The Fourth Circuit subsequently permitted Crawley to file a second 2255 motion challenging his 924(c) conviction and sentence in light of the Supreme Court’s 2015 holding that the residual clause of the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(2)(B)(ii), is unconstitutionally vague. While Crawley’s motion was pending, the Fourth Circuit concluded that conspiracy to commit Hobbs Act robbery is not a crime of violence under section 924(c)’s force clause and the crime of violence definition in section 924(c)’s residual clause is unconstitutionally vague. The Fourth Circuit affirmed that Crawley’s 924(c) conviction remained valid because it was predicated on the use, carrying, and brandishing of firearms during the charged drug trafficking crime.
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