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 frearm 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 defnitional 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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