Facts
- Woodrow Williams, Jr. was charged in a two-count federal indictment under 18 U.S.C. § 2113(a) (bank robbery) and § 2113(b) (bank larceny) for taking money from a federally insured bank branch in Cambridge, Maryland on December 4, 1970.
- On December 3, 1970, Williams drank heavily. That night he continued drinking and took six or seven barbiturate pills.
- Williams continued drinking into the next day and also took LSD pills before going to the bank.
- Before the bank incident, Williams went into a store and asked for a piece of paper. He tried to write on it, then balled it up and threw it on the floor.
- Williams asked for another piece of paper, wrote on it, and left the store. The store owner later saw the discarded paper, which read “This is a stick.”
- Williams then entered the Maryland National Bank and asked a branch officer for a Christmas loan. The loan request was denied.
- Bank employees who observed Williams stated that he smelled of alcohol and his eyes looked red or sleepy; they did not observe unusual walking, and one employee described his speech as understandable but somewhat slurred.
- After the loan denial, Williams approached teller Martina Bennett and handed her a note stating, “This is a stickup.”
- Bennett was intimidated by the note and gave Williams the cash from her drawer. Williams left the bank with the money.
- An audit showed $4,727 was taken.
- Williams did not dispute that he performed the acts constituting the taking; his defense was that intoxication from alcohol and drugs made him incapable of forming the intent required for the charged offenses.
- At the bench trial, psychiatrists testified for both sides about Williams’s impairment. One psychiatrist believed Williams knew what he was doing but had significantly impaired judgment and self-control due to intoxication; another stated Williams likely could not conform his conduct to the law at the time, and did not offer an opinion on whether Williams could form a specific intent to rob.
Issues
- Do 18 U.S.C. § 2113(a) and/or § 2113(b) require proof of a specific intent to steal such that voluntary intoxication may be considered on the intent element?
- If specific intent is required, did Williams’s intoxication create a reasonable doubt that he formed the intent to steal at the time of the bank robbery?
Decision
- The court held that both § 2113(a) and § 2113(b) require proof of a specific intent to steal, so evidence of voluntary intoxication was admissible and could be weighed on that question.
- The court found, based on all evidence, that Williams’s intoxication did not create a reasonable doubt about his intent to steal.
- The court found Williams guilty on both counts.
Legal Principles
- Voluntary intoxication is generally not a defense, but it may be considered when the charged offense includes a specific-intent element.
- Federal bank robbery under 18 U.S.C. § 2113(a) requires proof that the defendant intended to steal bank property; the government must prove that intent beyond a reasonable doubt.
- Federal bank larceny under 18 U.S.C. § 2113(b) also requires intent to steal or purloin; intoxication evidence may be relevant to whether that intent existed.
- The trier of fact may infer intent to steal from purposeful conduct before and during the taking, including planning activity and coherent steps used to obtain money by intimidation.
- Even where alcohol and drug use is substantial, the defense succeeds only if the impairment is so severe that it raises a reasonable doubt on the intent element.
Conclusion
The district court concluded that both bank robbery and bank larceny under 18 U.S.C. § 2113(a) and (b) require an intent to steal, so Williams’s evidence of intoxication was properly considered, but his goal-directed conduct—preparing a robbery note, seeking money at the bank, and obtaining $4,727 by intimidation—showed he still formed the required intent, and the court therefore found him guilty on both counts.