Whitfield v. United States
Docket No. 13-9026
Argument Date: Dec 2, 2014
ISSUE:
On December 2, 2014, the Supreme Court of United States will decide whether 18 U.S.C. § 2113(e), which applies to a bank robber who forces another person to accompany him while in flight from the crime scene, requires proof of more than a de minimis movement of the victim. § 2113(e) states: “whoever, in committing any offense defined in this section [bank robbery], … forces any person to accompany him without the consent of such person, shall be imprisoned not less than ten years, or if death results shall be punished by death or life imprisonment.” Federal circuit courts differ on how to interpret the words “to accompany him.” The Fifth and Tenth Circuits have held force-accompaniment only happens upon a showing of substantial movement of a victim as compared to what usually happens during a bank robbery. However, the Fourth Circuit held that this section applies to all forced movements no matter how insubstantial.
