13 January 2015

Law in Plain English: Whitfield v. United States

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

SCOTUSblogWhitfield v. United States

Argument: Dec 2 2014 (Aud.)

Background: Larry Whitfield and an accomplice tried (unsuccessfully) to rob a bank, and then fled. Whitfield ended up in the home of an elderly woman. After directing the woman to a room within her home, Whitfield tried to escape and was captured. The woman died of a heart attack. Whitfield was charged and convicted of 18 U.S.C. § 2113(e), the federal forced accompaniment statute. The Fourth Circuit affirmed.

Issue: The question before the Court is whether 18 U.S.C. § 2113(e), which provides a minimum sentence of ten years in prison and a maximum sentence of life imprisonment for a bank robber who forces another person “to accompany him” during the robbery or while in flight, requires proof of more than a de minimis movement of the victim.

Holding: In a unanimous decision, the Supreme Court ruled that a bank robber “forces [a] person to accompany him,” for purposes of §2113(e), when he forces that person to go somewhere with him, even if the movement occurs entirely within a single building or over a short distance (as was the case here).
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