Case Explained: UNITED STATES OF AMERICA v. CHRISTOPHER LLOYD

Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-08-12 The seventh-circuit vacated Christopher Lloyd’s sentence and remanded the case for resentencing because his prior Indiana conspiracy conviction did not categorically qualify as a “crime of violence” under U.S. Sentencing Guidelines § 4B1.2. Applying the categorical approach, the court held that the term “conspiring” in the Guidelines must be interpreted based on the generic definition of conspiracy as it existed at the time the relevant Guideline provision was enacted in 1989. The court determined that, in 1989, the generic offense of conspiracy required a bilateral agreement between two or more genuine participants to commit a crime. Because Indiana’s conspiracy statute criminalizes unilateral conspiracies—where an individual agrees with an undercover agent who does not genuinely intend to commit the offense—the state statute sweeps broader than the generic federal definition. Consequently, no conviction under Indiana’s conspiracy statute can serve as a predicate “crime of violence” for sentencing enhancements under § 4B1.2, regardless of whether the defendant’s specific conduct involved multiple genuine conspirators. The court rejected the government’s argument that the 2023 reorganization of the Guidelines should reset the relevant date to 2023, ruling that the amendment was non-substantive and did not alter the meaning of “conspiring.” Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.