Summary
The Sixth Circuit held that carjacking under 18 U.S.C. § 2119 qualifies as a crime of violence under § 924(c)’s elements clause because the “intimidation” element necessarily involves the threatened use of violent physical force. The court also vacated one of Jackson’s two § 924(c) convictions arising from simultaneous carjackings, ruling that a single use of a firearm during concurrent predicate offenses supports only one § 924(c) conviction under the unit-of-prosecution analysis in *United States v. Vichitvongsa*. The court affirmed the admission of gang-affiliation evidence to show motive under Rule 404(b), upheld a two-level sentencing enhancement for bodily injury based on a victim’s painful and obvious injuries, and rejected retroactive misjoinder and sufficiency-of-the-evidence challenges.