Completed Hobbs Act Robbery Remains a § 924(c) “Crime of Violence” After Taylor (11th Cir.)

1. Introduction

In United States v. Jordan Lewis (11th Cir. Jan. 15, 2026) (unpublished), the Eleventh Circuit addressed whether Hobbs Act robbery remains a qualifying “crime of violence” under 18 U.S.C. § 924(c)(3)(A) after the Supreme Court’s decision in United States v. Taylor, 596 U.S. 845 (2022). The appellant, Jordan Denzel Lewis, sought vacatur of his § 924(c) convictions for brandishing a firearm, arguing that Hobbs Act robbery cannot serve as the predicate “crime of violence.”

The Government moved for summary affirmance, asserting the issue was foreclosed by binding Eleventh Circuit precedent holding that completed Hobbs Act robbery satisfies § 924(c)’s elements clause.

2. Summary of the Opinion

The panel granted summary affirmance and affirmed Lewis’s convictions. Applying de novo review, the court held that, under binding circuit precedent, completed Hobbs Act robbery categorically qualifies as a “crime of violence” under § 924(c)(3)(A). The court concluded that Taylor—which held attempted Hobbs Act robbery is not a crime of violence—does not disturb Eleventh Circuit precedent as to the completed offense.

3. Analysis

3.1. Precedents Cited

Groendyke Transp., Inc. v. Davis, 406 F.2d 1158 (5th Cir. 1969)
The court invoked Groendyke to justify summary disposition when “the position of one of the parties is clearly right as a matter of law” and “there can be no substantial question as to the outcome.” This procedural authority supplied the mechanism for resolving the appeal without full briefing/argument once the court identified controlling precedent.
United States v. Wiley, 78 F.4th 1355 (11th Cir. 2023)
Cited for two propositions: (1) the standard of review (de novo) on whether an offense is a qualifying crime of violence under § 924(c); and (2) the merits holding that aiding and abetting Hobbs Act robbery is a crime of violence because completed Hobbs Act robbery remains a crime of violence after Taylor. The panel used Wiley as post-Taylor confirmation that circuit law continues to treat the completed offense as qualifying.
United States v. Gruezo, 66 F.4th 1284 (11th Cir. 2023) and United States v. Wilson, 979 F.3d 889 (11th Cir. 2020)
These cases were cited to frame the court’s discussion of subject-matter jurisdiction and the principle that an indictment charging a violation of a valid federal statute invokes federal jurisdiction. While not central to the Hobbs Act robbery question, they reinforce that once a valid federal statute is charged, jurisdiction exists; the fight is about the legal sufficiency of the § 924(c) predicate, not the court’s power.
United States v. Archer, 531 F.3d 1347 (11th Cir. 2008) and In re Lambrix, 776 F.3d 789 (11th Cir. 2015)
These cases supplied the governing prior-panel-precedent rule: later panels must follow earlier published panel holdings unless overruled en banc or by the Supreme Court, and litigants cannot evade precedent by arguing the earlier panel “overlooked” an argument. This doctrine was decisive because Lewis’s position required the panel to depart from earlier Eleventh Circuit holdings about completed Hobbs Act robbery.
St. Fleur, 824 F.3d 1337 (11th Cir. 2016)
The foundational Eleventh Circuit case holding Hobbs Act robbery “clearly” qualifies as a crime of violence under § 924(c)(3)(A)’s elements clause, because it has as an element the use, attempted use, or threatened use of physical force against person or property.
United States v. St. Hubert, 909 F.3d 335 (11th Cir. 2018), abrogated in part by United States v. Taylor, 596 U.S. 845, 853, 857-58 (2022)
St. Hubert reaffirmed that completed Hobbs Act robbery is a crime of violence and extended that logic to attempted Hobbs Act robbery; it also used a “realistic probability” analysis to reject hypotheticals of nonviolent Hobbs Act robbery. The panel noted Taylor abrogated parts of St. Hubert—specifically, its attempted-robbery holding and related reasoning—but treated the completed-robbery holdings as intact.
United States v. Taylor, 596 U.S. 845 (2022)
The Supreme Court held attempted Hobbs Act robbery is not categorically a crime of violence under § 924(c)(3)(A) because attempt liability requires intent plus a “substantial step,” which need not involve the use, attempted use, or threatened use of force. The Eleventh Circuit emphasized Taylor addressed attempt, not the completed offense, and therefore does not overrule circuit precedent on completed Hobbs Act robbery.
United States v. Solomon, 136 F.4th 1310 (11th Cir. 2025), petition for cert. filed, (U.S. Nov. 12, 2025) (No. 25-6089)
The key, most recent circuit authority relied on by the panel. Solomon “confirmed” that Taylor “says nothing of the completed crime” and thus does not disturb Eleventh Circuit precedent holding completed Hobbs Act robbery is a crime of violence. Solomon also rejected attempts to distinguish controlling precedent by raising “new arguments” not considered earlier—reinforcing Lambrix in this context.

3.2. Legal Reasoning

The decision proceeds in a tightly constrained, precedent-driven sequence:

Define the governing statutory test.
Section 924(c) applies when a firearm is used/carried/brandished during a qualifying predicate “crime of violence,” defined in § 924(c)(3)(A) (the “elements clause”) as a felony that has as an element the use, attempted use, or threatened use of physical force against person or property.
Identify the predicate offense’s elements.
The Hobbs Act’s definition of robbery includes taking property “by means of actual or threatened force, or violence, or fear of injury” to person or property. The panel treats this as matching the elements-clause requirement.
Apply binding circuit precedent.
Under St. Fleur (and reaffirmations such as St. Hubert for the completed offense), Hobbs Act robbery qualifies under the elements clause. Under the prior-panel-precedent rule (Archer; Lambrix), the panel cannot revisit that holding unless a Supreme Court decision or en banc decision undermines it to the point of abrogation.
Address the claimed intervening Supreme Court authority.
The panel reads Taylor narrowly as resolving only the status of attempted Hobbs Act robbery. Because Taylor did not decide the completed offense, it does not abrogate the circuit’s completed-robbery holdings. The panel relies heavily on Wiley and especially Solomon for that point.
Conclude there is no substantial question—summary affirmance is proper.
With the merits controlled by precedent, the Government is “clearly right as a matter of law” under Groendyke Transp., Inc., justifying summary affirmance.

3.3. Impact

Although unpublished, the opinion illustrates and reinforces a practical rule in the Eleventh Circuit: post-Taylor challenges to § 924(c) convictions predicated on completed Hobbs Act robbery are foreclosed by binding circuit precedent, as reiterated in Wiley and Solomon. The case also signals that appellants should expect summary affirmance when their arguments directly conflict with controlling precedent.

More broadly, the opinion underscores the institutional role of the prior-panel-precedent rule in limiting litigation churn after major Supreme Court decisions: even when a Supreme Court case (here, Taylor) reshapes part of the doctrine (attempt liability), it does not reopen adjacent questions (completed robbery) unless it clearly speaks to them.

The ultimate “impact” question may shift to the Supreme Court: because Solomon noted a pending certiorari petition, future developments may depend on whether the Court takes up (and how it frames) the completed Hobbs Act robbery issue.

4. Complex Concepts Simplified

§ 924(c) “elements clause” (§ 924(c)(3)(A)): A predicate crime qualifies if, by its legal definition, it necessarily involves using, trying to use, or threatening physical force against a person or property.
“Categorically” / categorical approach: Courts look to the statutory elements of the offense (the minimum conduct required for conviction), not the defendant’s actual real-world conduct.
Attempt vs. completed offense: “Attempt” typically requires intent plus a “substantial step,” which may occur without force or threats. A “completed” robbery, by definition, involves accomplishing the taking by force/threats/fear of injury (as the Eleventh Circuit reads the Hobbs Act).
Aiding and abetting (18 U.S.C. § 2(a)): Treats a person who intentionally helps commit the crime as legally guilty of the crime itself. In Wiley, this mattered because aiding and abetting a completed Hobbs Act robbery inherits the completed offense’s “crime of violence” status.
Prior-panel-precedent rule: A later three-judge panel must follow earlier published panel decisions unless overruled by the Supreme Court or the Eleventh Circuit sitting en banc.
Abrogation: When a higher court decision undermines a precedent so directly that it can no longer be followed. The panel held Taylor abrogated parts of St. Hubert (attempt), but not the holdings about completed Hobbs Act robbery.
Summary affirmance: An expedited affirmance used when the legal outcome is clear and further proceedings would not change the result.

5. Conclusion

United States v. Jordan Lewis applies the Eleventh Circuit’s prior-panel-precedent framework to hold that completed Hobbs Act robbery remains a § 924(c)(3)(A) “crime of violence” after United States v. Taylor. The panel’s reliance on St. Fleur, and its post-Taylor reaffirmations in Wiley and Solomon, leaves little room—absent en banc or Supreme Court intervention— for defendants in this circuit to invalidate § 924(c) convictions predicated on completed Hobbs Act robbery.