In United States v. Jy’Quale Samari Grable, No. 23-10544 (11th Cir. Jan. 5, 2026) (Jordan, Lagoa, Tjoflat) the Court held “that a taking of property does not constitute robbery under the Hobbs Act unless force or threatened force is used before or during the taking.” And, because Mr. Grable had “used force” (shot and killed two victims) “only after one of his co-conspirators had stolen marijuana and carried it away,” the Court set aside his substantive § 1951(a) conviction, as well as his 18 U.S.C. § 924(c) & (j) convictions, which were premised on the alleged robbery. The Court thus also vacated his life plus twenty-year sentences as to the §§ 924(c) & (j) & 1951(a) convictions. The Court affirmed Mr. Grable’s conviction and 20-year sentence for HAR conspiracy.
Full opinion here: https://media.ca11.uscourts.gov/opinions/pub/files/202310544.pdf