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United States v. Hill

927 F.3d 188 (2019)

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United States v. Hill

United States Court of Appeals for the Fourth Circuit

927 F.3d 188 (2019)

Facts

James Hill, III (defendant) punched his coworker Curtis Tibbs while both were at work at an Amazon fulfillment center in Virginia. Tibbs was carrying boxes to be prepared for shipping when Hill punched him, which caused the boxes to fly into the air. Tibbs suffered multiple bruises and cuts. Tibbs missed the remainder of his shift, and the work area was closed briefly for cleaning. Amazon did not miss any deadlines or lose productivity as a result of the assault on Tibbs, because other employees covered his workload. Hill told an Amazon internal investigator and the police that he assaulted Tibbs because he believed Tibbs was homosexual. Virginia’s state hate-crime law did not cover crimes motivated by sexual orientation, so the case was referred to prosecutors of the United States (plaintiff). Hill was indicted under the Hate Crimes Prevention Act of 2009 (the statute) for his assault of Tibbs. At trial, the federal district court told the jury that to convict Hill the jury must find that at the time of the assault Tibbs was engaged in, and Hill interfered with, commercial activity. Hill was convicted and filed a motion for acquittal, arguing that the statute could not be constitutionally applied to his conduct. The district court granted Hill’s motion, finding that Hill’s conduct could not be subjected to federal prosecution as a violation of the statute. The district court found that such a prosecution would exceed Congress’s Commerce Clause authority because Hill did not substantially interfere with interstate commerce. The government appealed.

Rule of Law

Issue

Holding and Reasoning (Wynn, J.)

Dissent (Agee, J.)

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