This is Malek Lassiter’s second appeal from his nine convictions. On his first trip to this Court, we reversed four of Lassiter’s nine counts. See United States v. Simmons, 11 F.4th 239 , 248 (4th Cir. 2021). Now, he asks us to reverse two more: convictions for possessing a firearm in furtherance of a crime of violence under 18 U.S.C. § 924 (c)(1)(A).

But Lassiter didn’t challenge these convictions in the district court or in his first appeal, so his appeal triggers both plain-error review and the mandate rule. He seeks to evade these bars by arguing that a dramatic change in legal authority has rendered his convictions plainly erroneous.

According to Lassiter, the Supreme Court’s decision in United States v. Taylor, 596 U.S. 845 (2022), dramatically changed what constitutes a “crime of violence” when it held that attempted Hobbs Act robbery isn’t such an offense. This change, Lassiter says, means that attempted murder in aid of racketeering activity (“VICAR attempted murder”)—on which his § 924(c)(1)(A) convictions were predicated—is not a crime of vi