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Brooklyn Federal Judge Rejects Hobbs Act Robbery as Predicate for 'Career Criminal' Enhanced Sentence

U.S. District Court Judge Eric Vitaliano of the Eastern District of New York ruled that Hobbs Act robbery does not qualify as a "violent felony" under the Armed Career Criminal Act, finding the offense too broad under the categorical approach because it can be committed against property. The U.S. Court of Appeals for the Second Circuit has not yet weighed in on this issue.