United States v. Williams, No. 17-3040 (8th Cir. 2018)Annotate this Case
The Eighth Circuit affirmed defendant's conviction and sentence for conspiracy to distribute and possess with intent to distribute marijuana, interference with commerce by robbery (or a Hobbs Act robbery), using and carrying a firearm during and in relation to a drug-trafficking offense or a crime of violence, and being a felon in possession of a firearm. Defendant's crimes stemmed from a robbery and shooting of an individual from whom defendant had arranged to purchase a large amount of marijuana.
The court held that the evidence was sufficient to convict defendant of the crimes; because the court affirmed defendant's conviction for conspiracy to possess with intent to distribute, which was undisputedly a drug-trafficking offense, the predicate offense necessitated by 18 U.S.C. 924(c) was satisfied without regard to whether a Hobbs Act robbery qualified as a crime of violence; and, although defendant's 150 month sentence exceeded the 60 month statutory maximum based upon the quantity of marijuana involved, defendant failed to show the prejudice required to vacate his sentence.