Bowe v. United States · ¶13

Bowe, acting pro se, initially sought postconviction relief under § 2255 in 2016, before the Court decided Davis, arguing that the residual clause is unconstitutionally vague. A District Court rejected Bowe's claim, in part, because regardless of the residual clause's constitutionality, attempted Hobbs Act robbery qualified as a crime of violence under § 924(c)'s elements clause. App. 43.

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