Eighth Circuit: United States v. Levon Dean, Jr.

Hobbs Act robbery.

Where a statute has an express nexus to interstate commerce, the actual connection can be small; in this case, it suffices that the robbery affected the victim's ability to participate in interstate drug purchases.

Sufficient connection between the crimes for a common conspiracy, but harmless error, as participants were principals in both actions.

Because victim was hit rather hard on the head, there was sufficient bodily injury for the carjacking statute - injury need not be in or near the car.

As codeft had a distinctive walk while carrying a gun, sufficient evidence for knowledge of the gun.

Intent to affect interstate drug commerce not a necessary jury instruction for conspiracy count.

Constructive possession / vehicle instruction upheld.

Hearsay evidence properly considered in sentencing.

Sentencing court's denial of de minimis sentence for counts not subject to mandatory minimums was proper, despite the fact that the court stated that it did not have the power to impose a de minimis sentence.

http://media.ca8.uscourts.gov/opndir/15/12/151263P.pdf