Bowe v. United States · ¶1
Petitioner Michael S. Bowe is serving a 24-year sentence in federal custody after pleading guilty in 2008 to three offenses: (1) conspiracy to commit Hobbs Act robbery; (2) attempted Hobbs Act robbery; and (3) using a firearm in relation to a “crime of violence” as defined in 18 U. S. C. §924(c)(1)(A). Bowe’s §924(c) conviction carried a mandatory 10-year sentence to be served consecutively to his sentence for the robbery offenses. To have been properly convicted under §924(c), at least one of Bowe’s other offenses must qualify as a “crime of violence” under one of two definitional clauses in §924(c): the “elements clause,” §924(c)(3)(A), or the “residual clause,” §924(c)(3)(B). But decisions issued years after Bowe’s conviction call into question whether either clause can support his §924(c) conviction. See United States v. Davis, 588 U. S. 445, 470 (residual clause void for…Read in context ›
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