US v. Taylor: Taylor was part of a group that planned to rob drug dealers. The only problem (well, the first problem) is that the people they targeted for robberies didn't really have much to take. During a first robbery, they made off with $40, some jewelry, two cell phones, and a joint. During the second, they managed only a cell phone. Both robberies involved pistol whipping, groping, and holding a six-year old at gunpoint. Taylor was charged with two counts of robbery under the Hobbs Act and two counts of using a firearm in furtherance of a crime of violence. After a first trial ended in a mistrial, the Government successfully precluded Taylor from offering evidence that the drugs involved in the robberies was marijuana that was grown in the same state, and thus did not affect interstate commerce. Taylor was convicted on all counts, save one of the gun counts, and sentenced to 336 months in prison.
On appeal, Taylor argued that there was insufficient evidence that the robberies affected interstate commerce and that he should have been allowed to put on evidence of the marijuana's in-state origin. The Fourth Circuit rejected both those arguments and affirmed. First, it concluded that there was sufficient evidence that the targets of the robberies were drug dealers and that Taylor "depleted or attempted to deplete" their assets during the robberies. In addition, the items taken during the robberies, while not of significant value, were enough "to meet the de minimis standard under the depletion-of-assets theory." Second, it concluded that the district court did not abuse its discretion by limiting the evidence Taylor could present about the source of the marijuana.