In United States v. Walker, the 3rd Circuit addressed whether an attempt to commit a crime of violence categorically qualified as a crime of violence itself. The defendant asserted that attempted Hobbs Act robbery cannot serve as a valid predicate crime of violence under 18 U.S.C. § 924(c). He reasoned that a person could be convicted for attempted Hobbs Act robbery based on nothing more than an intent to complete the robbery and a non-violent substantial step – in other words, without actually committing a violent act and with only the intent to do so. The 3rd Circuit affirmed the conviction and joined the majority of circuits that have considered the issue. The 3rd Circuit held that, given the plain language of § 924(c), attempted Hobbs Act robbery is categorically a crime of violence.
