Whitfield v. United States

Federal law establishes enhanced penalties for anyone who "forces any person to accompany him" in the course of committing or fleeing from a bank robbery. 18 U.S.C. § 2113 (e). We consider whether this provision applies when a bank robber forces someone to move with him over a short distance.

I

Petitioner Larry Whitfield, fleeing police after a botched bank robbery, entered the home of 79-year-old Mary Parnell through an unlocked door. Once inside, he encountered a terrified Parnell and guided her from the hallway to a computer room (which Whitfield estimates was between four and nine feet…