After a botched bank robbery, Whitfield fled into the home of Mary Parnell. Once inside, he guided Ms. Parnell from the hallway to a computer room, a distance of between 4 and 9 feet. Whitfield argued that the word “accompany” as used in § 2113(e), required substantial movement and that his short trip with Ms. Parnell did not qualify. The Fourth Circuit Court of Appeals disagreed concluding that, “[a]lthough Whitfield required Mrs. Parnell to accompany him for only a short distance within her own home, and for a brief period, no more is required to prove that a forced accompaniment occurred.” The Supreme Court agreed, observing that it is “natural to speak of accompanying someone over a relatively short distance, for example: from one area within a bank ‘to the vault.’” For this proposition the Court cited a story titled, “Addison State Bank Robbed” that appeared in the April 6, 1928, issue of the DuPage County Register. The article stated that the “bandit accompanied [the teller] to the vault.”
Justice Scalia and his clerks deserve credit for finding this 87 year old story in an obscure and defunct newspaper. But with the internet not much stays hidden. The 1928 article is here.
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