Whitfield v. United States
574 U.S. 265
SCOTUS2015Background
- Petitioner Larry Whitfield, fleeing a botched bank robbery, entered Mary Parnell’s home and guided her from a hallway to a nearby computer room (about 4–9 feet). Parnell suffered a fatal heart attack there.
- Whitfield was indicted and convicted under 18 U.S.C. §2113(e) for "forc[ing] any person to accompany him" in the course of fleeing a bank robbery.
- Whitfield argued on appeal that §2113(e) requires "substantial" movement and that the short, in-home movement did not qualify.
- The Fourth Circuit upheld the conviction, holding that short-distance, in-building movement sufficed.
- The Supreme Court granted certiorari to decide the meaning of "accompany" in §2113(e) and whether it requires movement over a substantial distance.
Issues
| Issue | Whitfield's Argument | United States' Argument | Held |
|---|---|---|---|
| Whether §2113(e)’s phrase "forces any person to accompany him" requires movement over a substantial distance | "Accompany" should be read to require substantial distance; short in-home movement doesn’t qualify | "Accompany" means to "go with" someone; no distance requirement beyond moving from one place to another | The Court held no substantial-distance requirement: forcing someone to go somewhere with the robber—even a short distance within a building—satisfies §2113(e) |
| Whether the statute’s severe penalties compel a narrow reading of "accompany" | Severe mandatory minimum and potential life sentence mean Congress intended a narrower scope | Severity does not indicate a distance element; danger can exist regardless of distance | Court rejected narrowing based on penalty severity, noting risk does not depend on distance |
| Whether reading "accompany" broadly renders other §2113 subsections superfluous | Broad reading would subsume many §2113(a)/(d) prosecutions, making them redundant | Subsections (a), (d), and (e) target distinct conduct; not all control over victims equals forcing accompaniment | Court held the provisions cover distinct conduct and a broad reading of "accompany" does not make other subsections superfluous |
| Sufficiency of evidence that Whitfield forced Parnell to accompany him | Movement was too brief/short to constitute "accompanying" | Forcing Parnell to move several feet from one room to another satisfied "accompany" | Court found movement of several feet within the house met §2113(e); conviction affirmed |
Key Cases Cited
- Carter v. United States, 530 U.S. 255 (2000) (discussed historical context of bank-robbery statutes)
- Vermont Agency of Natural Resources v. United States ex rel. Stevens, 529 U.S. 765 (2000) (statutory text presumed to retain original meaning absent change)
- United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (1906) (syllabus does not form part of Court’s opinion)
- Vernonia School Dist. 47J v. Acton, 515 U.S. 646 (1995) (example usage of "accompanied by" cited for ordinary meaning)