Whitfield v. United States

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Criminal Law
  • Date Filed: January 13, 2015
  • Case #: 13-9026
  • Judge(s)/Court Below: Scalia, J., delivered the opinion for a unanimous Court.
  • Full Text Opinion

The word "accompany" in 18 U.S.C. §2113, which creates increased penalties for actions taken during the commission of, or flight from, a bank robbery, means "to go with" even over short distances.

While eluding capture after a failed bank robbery, Petitioner entered the home of a 79-year-old woman. There he moved her a short distance into another room where she died of a heart attack. Federal law provides a mandatory minimum 10-year sentence when a bank robber “forces a person to accompany him” during the robbery or flight thereafter. After pleading not guilty, Petitioner was convicted by a jury. On appeal he argued that the severity of the punishment carried by this aggravating factor must require accompaniment over a substantial distance, and that it should not apply to his moving his victim into the next room. The Fourth Circuit disagreed, affirming the trial court.

The Supreme Court affirmed the lower courts holding that “accompany” means “to go with” even over short distances. The Court referred to newspaper articles, a wedding announcement, the dictionary, and British Literature classics to illustrate the clear meaning of the word “accompany.” In response to Petitioner’s argument regarding the severity of this aggravating factor the Court states, “It is simply not in accord with English usage to give ‘accompany’ a meaning that covers only large distances.”

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