United States v. William Nathaniel Cobb

Citations: 144 F.3d 319; 1998 U.S. App. LEXIS 9873; 1998 WL 246141Docket: 96-4969

Court: Court of Appeals for the Fourth Circuit; May 18, 1998; Federal Appellate Court

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William Nathaniel Cobb was convicted of carjacking, use of a firearm during a crime of violence, and bank fraud. He appealed the district court's denial of his motion to dismiss the carjacking and firearm counts, arguing that the federal carjacking statute exceeded Congress' authority under the Commerce Clause. The Fourth Circuit Court of Appeals affirmed the district court's judgment, determining that the carjacking statute fell within Congress' commerce power.

On October 6, 1995, Cobb carjacked Amanda Yezerski at a gas station in South Carolina, where he threatened her with a gun and forcibly took her vehicle. After the incident, Cobb used Yezerski's debit card for purchases and attempted to withdraw cash using her ATM card. He was arrested and indicted on multiple counts, including carjacking and bank fraud. Following the trial, during which he was found guilty on all counts, he received a total sentence of 248 months. Cobb's appeal centered on the constitutionality of the federal carjacking statute, which the court upheld.

Cobb committed acts that fell under the federal carjacking statute, which criminalizes taking a motor vehicle from another through force or intimidation, with varying penalties based on the severity of the outcome (up to life imprisonment if death results). Cobb challenges the statute's constitutionality, arguing it exceeds Congress' commerce power as defined in United States v. Lopez. However, the court finds this challenge unfounded, asserting that the statute includes a jurisdictional element linking the conduct to interstate commerce, thus aligning with Congress' authority to regulate instrumentalities and activities affecting interstate commerce. The court distinguishes this case from Lopez, noting that section 2119 explicitly ensures a connection to interstate commerce, countering Cobb’s arguments. The significance of jurisdictional elements in criminal statutes is reinforced by precedents such as United States v. Bass and Scarborough v. United States, which establish the necessity of proving a nexus with interstate commerce for criminal conduct.

The court addressed the constitutionality of 18 U.S.C. § 2119, the federal carjacking statute, in relation to the Commerce Clause, referencing United States v. Wells. The court upheld that § 2119's jurisdictional element, which requires proof that the stolen vehicle was transported in interstate commerce, distinguishes the case from United States v. Lopez, thus satisfying the minimal nexus required by the Commerce Clause. The government demonstrated that the vehicle in question was manufactured in Ohio and shipped to South Carolina. 

The court also affirmed that § 2119 is a valid exercise of Congress’ power to regulate instrumentalities of interstate commerce, citing that automobiles, like trains and aircraft, are essential for the interstate movement of goods and people. The court noted that the classification of cars as instrumentalities of interstate commerce is consistent with decisions from four other circuits. The ruling concluded by affirming the district court's judgment, stating that prior sentencing issues raised by Cobb were conceded as correct by his counsel, leaving only the constitutional challenge to be addressed.

Section 2119's jurisdictional element meets the nexus required by the Commerce Clause and regulates an instrumentality of interstate commerce. Consequently, it is unnecessary to determine if the statute can also be justified as a regulation of activities that substantially affect interstate commerce. This conclusion aligns with rulings from four other circuits. The judgment of the district court is affirmed. Although Cobb initially raised issues regarding sentencing, his counsel conceded that the district court's sentence was correct, leaving only the constitutional challenge to address.