Whitfield v U.S.

Posted: March 1, 2015 by beguide in case summaries, Criminal Procedure, Guns


WHAT HAPPENED: Whitfield is a criminal defendant who was charged with a calamitous robbery, which took Whitfield from a Federal Credit Union through the houses of neighboring residents.   While in the home of a nearby bystander, Whitfield asked the bystander to nominally move throughout the room the neighbor was found in. The neighbor moved slightly but remained in the home. Because of these actions, Whitfield was indicted with the aggravated charge of forcing a third party to accompany the defendant during a robbery.

WHY IS THIS BEFORE THE SUPREME COURT: The Due Process clause of the 5th Amendment requires that criminal laws are fairly specific, so that a citizen could not be found guilty of conduct that they were unaware was a crime at the time it was committed. This is usually phrased on the context of “vagueness”. Whitfield argues that the phrase “accompany” is unconstitutional vague because the word could represent any kind of movement, as evidenced by Whitfield’s liability in this case. Whitfield only asked the third party to move nominally around the house and did not force the third party around like a hostage, which one would assume was the focus of this aggravating crime.

WHAT ARE THE RAMIFICATIONS OF THIS DECISION: This case would affect the Court’s ability to interpret criminal statutes, but ultimately is fairly limited to the scope of this particular statute. This case has some connection to Johnson v. U.S., which deals with the Court’s ability to interpret criminal statutes to their liking.

WHAT WAS THE RULING: The Court ruled 9-0 in favor of the government and upheld Whitfield’s conviction. Justice Alito wrote the opinion stating that the word “accompany” included any form of movement, and stated that the amount of movement in the Whitfield case satisfied the statute for which he was convicted.

THE GOOD GUYS WON IF YOU: are a fan of common sense and Webster’s dictionary.

THE BAD GUYS WON IF YOU: are a bumbling bank robber, or are a criminal defense attorney who represents bumbling bank robbers.

WHO WAS RIGHT: This case was decided prior to recording, but both Brett and Nazim agreed with the holding.


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