United States v. Williams
332 F. Supp. 1 (1971)
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Rule of Law:
Robbery by force, violence, or intimidation under 18 U.S.C. § 2113(a) is a general intent crime for which voluntary intoxication is not a defense. In contrast, bank larceny under § 2113(b) requires a specific intent to steal, which may be negated by evidence of severe intoxication.
Facts:
- Following an argument with his wife, the defendant began drinking large quantities of whiskey and taking barbiturates and LSD over the course of approximately 28 hours.
- On December 4, 1970, the defendant went to a store where he obtained a piece of paper and wrote a note, discarding his first attempt which read 'This is a stick.'
- The defendant then entered a branch of the Maryland National Bank and spoke with loan officer John Bramble to request a loan, which was denied.
- After the denial, the defendant approached teller Martina Bennett and handed her a note which read, 'This is a stickup.'
- Mrs. Bennett, believing the defendant had a gun and fearing for her safety, gave him $4,727 from her cash drawer.
- The defendant took the money, left the bank, and later hired a taxi driver to take him to South Carolina, telling the driver that the money was from five years of work in Vietnam.
Procedural Posture:
- The defendant was charged in the U.S. District Court for the District of Maryland in a two-count indictment for violating 18 U.S.C. § 2113(a) (robbery by intimidation) and § 2113(b) (taking with intent to steal).
- The defendant stipulated to the factual acts of the robbery but pleaded not guilty, asserting that his intoxication prevented him from forming the necessary criminal intent.
- The case was tried non-jury before a district judge.
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Issue:
Does voluntary intoxication serve as a valid defense to charges under the federal bank robbery statute, 18 U.S.C. § 2113(a) and (b), by negating the required criminal intent?
Opinions:
Majority - Herbert F. Murray
No as to § 2113(a); Yes as to § 2113(b). Voluntary intoxication is not a defense to robbery by intimidation under § 2113(a) because it is a general intent crime, but it can be a defense to larceny under § 2113(b) because that offense requires a specific intent to steal. The court distinguishes between the subsections of the federal bank robbery statute based on their express language. Subsection (a), which prohibits taking by force, violence, or intimidation, does not contain an explicit intent element and describes an act so 'unambiguously dangerous' that the requisite mental element is implicit. Therefore, it is a general intent crime, and voluntary intoxication is no defense. In contrast, subsection (b) contains the specific language 'with intent to steal or purloin,' making it a specific intent crime. For such crimes, evidence of intoxication can be introduced to show the defendant was incapable of forming the requisite intent. However, applying this rule to the facts, the court finds beyond a reasonable doubt that the defendant, despite his consumption of alcohol and drugs, was not so intoxicated as to negate his specific intent to steal. His purposeful actions—writing the note, conversing coherently, carrying out the robbery, escaping, and creating a cover story for the money—demonstrated that he had the capacity to, and did, form the necessary intent.
Analysis:
This opinion provides a clear framework for analyzing mens rea requirements within a multi-part criminal statute by focusing on precise statutory language. It solidifies the distinction between general and specific intent crimes, establishing that the defense of voluntary intoxication is unavailable for the general intent crime of bank robbery by intimidation under § 2113(a). By contrast, it affirms that the specific intent language in § 2113(b) preserves the intoxication defense for that charge. This decision guides future courts in interpreting federal criminal statutes, emphasizing that the presence or absence of explicit words like 'with intent' is determinative of the level of intent the prosecution must prove and the defenses available to the defendant.
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