Grimes v. United States

MESKILL, Circuit Judge:

This appeal raises interesting questions regarding the proper relationship between two specific sections of the Federal Bank Robbery Act — 18 U.S.C. § 2113(a) (bank robbery) and 18 U.S.C. § 2113(d) (armed bank robbery) — as well as the relationship between § 2113(d) and part of the Gun Control Act of 1968 — 18 U.S.C. § 924(c)(1) (use of a firearm to commit a felony). For the reasons that follow, we hold that separate judgments of conviction for bank robbery and armed bank robbery may not be entered when those convictions arise out of a single criminal transaction. We…