United States v. Needham

B.D. PARKER. JR., Circuit Judge:

Defendants-appellants Derrilyn Need-ham, Javier Robles, and Corey Thompson appeal from judgments of conviction in the United States District Court for the Southern District of New York (Lynch, J.) for Hobbs Act robbery and related offenses. See 18 U.S.C. §§ 1951, 1952. They challenge their convictions based on an instruction that foreclosed the jury’s consideration of an essential jurisdictional element of Hobbs Act robbery: whether the robberies, which targeted the proceeds of drug trafficking, affected interstate commerce.

This case presents a situation that…