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  • Whitfield V U S Brief

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    The Supreme Court ruled that the penalty enhancement for forced accompaniment during a bank robbery can apply even if the person was only forced to move a short distance or within the same building. The case involved a defendant who fled a bank robbery and forced a woman into another room in her home, where she then had a fatal heart attack. While the defendant argued the accompaniment was too short a distance, the Court examined the original meaning and dictionary definition of "accompany," finding it does not necessarily mean substantial movement, so the defendant did force the woman to accompany him as intended by the statute.

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    whitfield v u s brief

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    The Supreme Court ruled that the penalty enhancement for forced accompaniment during a bank robbery can apply even if the person was only forced to move a short distance or within the same building. The case involved a defendant who fled a bank robbery and forced a woman into another room in her home, where she then had a fatal heart attack. While the defendant argued the accompaniment was too short a distance, the Court examined the original meaning and dictionary definition of "accompany," finding it does not necessarily mean substantial movement, so the defendant did force the woman to accompany him as intended by the statute.

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    © All Rights Reserved
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    13 views1 page

    Whitfield V U S Brief

    Uploaded by

    api-317269928
    The Supreme Court ruled that the penalty enhancement for forced accompaniment during a bank robbery can apply even if the person was only forced to move a short distance or within the same building. The case involved a defendant who fled a bank robbery and forced a woman into another room in her home, where she then had a fatal heart attack. While the defendant argued the accompaniment was too short a distance, the Court examined the original meaning and dictionary definition of "accompany," finding it does not necessarily mean substantial movement, so the defendant did force the woman to accompany him as intended by the statute.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
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    Citation

    Facts

    Whitfield v. United States, 574 U.S. ___ (2015)


    Substantive: In the course of fleeing a bank robbery, the
    defendant entered a womans home and forced her into another
    room, where she then suffered a fatal heart attack.
    Procedural: The defendant was convicted at the trial level and
    appealed to the U.S. Court of Appeals for the Fourth Circuit,
    which affirmed the district courts conviction. The defendant
    subsequently petitioned the U.S. Supreme Court for Writ of
    Certiorari.

    Issue

    Whether the forced accompaniment penalty enhancement in a


    federal bank robbery charge applies in cases when a bank robber
    forces a person to accompany him over a short distance or
    within the same building.

    Short Answer

    Yes; the U.S. Supreme Court ruled that the forced


    accompaniment offense does not require substantial movement.

    Reasoning

    Rule: The forced accompaniment penalty enhancement was


    enacted by Congress in 1934 under 18 U.S.C. 2113(e) in
    response to a string of bank robberies committed by John
    Dillinger. The Court noted that, despite numerous amendments to
    Section 2113, the statutory language of the forced accompaniment
    provision has remained unchanged, and so presumptively retains
    its original meaning. In consulting the Oxford English
    Dictionary and examining various uses of the word in English
    literature, the Court said the definition of the word accompany
    does not necessarily connote movement over a great distance.
    Analysis: In this case, although the defendant only forced the
    woman to move a short distance with him within the same
    building, the scope of the word accompany, as the word is
    commonly used, is not limited to movement over a great distance.
    Conclusion: Therefore, the defendant did, under conventional use
    of the word, force the woman to accompany him, and he was
    appropriately convicted.

    Holding

    The Court held that the forced accompaniment penalty


    enhancement is applicable and appropriate in cases when a bank
    robber forces another person to accompany him, even if
    accompaniment is just a short distance or within the same
    building.

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