US v. Lassiter, No. 22-4147 (4th Cir. 2024)
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This case was brought before the United States Court of Appeals for the Fourth Circuit, where the defendant, Malek Lassiter, appealed his convictions for possessing a firearm in furtherance of a crime of violence under 18 U.S.C. § 924(c)(1)(A). Lassiter argued that his convictions were erroneous due to a change in legal authority in the form of the Supreme Court decision in United States v. Taylor which altered the definition of a "crime of violence".
Lassiter's convictions were based on attempted murder in aid of racketeering activity, arguing that this did not constitute a crime of violence in light of the Taylor decision. However, the court disagreed, distinguishing between the requirements for attempted Hobbs Act robbery, which was the focus of the Taylor case, and murder, asserting that murder requires the use of force, therefore attempted murder necessarily requires the attempted use of force, fitting within the definition of a crime of violence.
The court rejected Lassiter's arguments and affirmed his § 924(c)(1)(A) convictions. However, due to an inconsistency between the oral and written descriptions of one of Lassiter’s supervised-release conditions, the court vacated his sentence in its entirety and remanded the case for a full resentencing.
The court issued a subsequent related opinion or order on March 20, 2024.
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