US v. Michael Draven, No. 21-7171 (4th Cir. 2023)
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Defendant was convicted of conspiracy to commit murder for hire resulting in death, aiding and abetting carjacking resulting in death, and aiding and abetting murder with a firearm in relation to a crime of violence. The first two convictions served as the predicate offenses for Defendant's third conviction.
Defendant filed a motion to vacate, arguing that following the Supreme Court’s decisions in United States v. Davis, 139 S. Ct. 2319 (2019), and United States v. Taylor, 142 S. Ct. 2015 (2022), his predicate offenses no longer qualify as crimes of violence.
The Fourth Circuit affirmed, finding that aiding and abetting carjacking resulting in death remains a valid predicate offense under
18 USC 924(c)(3)(A).
The court issued a subsequent related opinion or order on August 11, 2023.
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