Does a conviction for carjacking by 'force and violence' under 18 U.S.C. § 2119 require that the force and violence be employed, with the requisite intent to seriously harm or kill, for the purpose of taking a vehicle?

QUESTION PRESENTED Petitioner Brian Jones pleaded guilty to violating the federal carjacking statute, 18 U.S.C. § 2119, but the facts of his case were far from a typical “carjacking.” Mr. Jones and the victim were friends, and they were riding in the victim’s car together because the victim was helping Mr. Jones move. However, while en route to their destination, the victim took a detour to a house where other people attacked and robbed Mr. Jones. When he returned to the car, Mr. Jones began arguing with the victim as they continued their drive, believing that his friend set him up to be ambushed. Mr. Jones eventually told the victim to stop at an intersection in his neighborhood, and they both exited the car. Then, as the victim began to retrieve Mr. Jones’s belongings from the trunk, Mr. Jones abruptly attacked him as retribution for what transpired. After the assault, Mr. Jones took the victim’s keys, drove his car away from the scene, and abandoned it several blocks away after attempting to destroy it. The Fifth Circuit affirmed Mr. Jones’s carjacking conviction, holding that § 2119’s intent requirement “does not mandate that a defendant intend to kill or cause serious injury in furtherance of taking a vehicle.” App’x at 5a. Thus, according to the Fifth Circuit, it made no difference whether Mr. Jones’s clear intent and motivation in the assault was personal and unrelated to taking the car. The question presented is: Does a conviction for carjacking by “force and violence” under 18 U.S.C. § 2119 require that the force and violence be employed, with the requisite intent to seriously harm or kill, for the purpose of taking a vehicle? ii