Whitfield v. United States - Post-Decision SCOTUScast

On January 13, 2015, the Supreme Court issued its decision in Whitfield v. United States. This case concerns 18 U.S.C. § 2113(e), which provides a minimum sentence of ten years and a maximum sentence of life imprisonment for a bank robber who forces another person “to accompany him” during the robbery or while fleeing the scene.  The question is whether the requirement that the robber force another person “to accompany him” requires proof of more than a minimal movement of the victim.

Justice Scalia delivered the opinion for a unanimous Court, which held that a bank robber, for purposes of §2113(e), “forces [a] person to accompany him,” when he compels that person to go somewhere with him, even if the movement occurs entirely within a single building or over a short distance.

To discuss the case, we have Professor John Stinneford, who is Associate Professor of Law and Assistant Director of the Criminal Justice Center at the University of Florida Levin College of Law.

As always, the Federalist Society takes no position on particular legal or public policy issues; all expressions of opinion are those of the speaker.

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