Holloway V. United States - Decision

Decision

The Court decided in a 7-2 decision that the federal carjacking law does apply to carjacking crimes committed by defendants with the "conditional intent" of harming drivers who resist the hijacker. The requirement of intent is satisfied if the government proves that at the moment the crime is committed, the defendant possessed the intent to seriously harm or kill the driver if this was necessary to steal the car. The court's reasoning was that the federal statute's element of mens rea is directed at the defendant's state of mind at that moment in time when he hijacks the vehicle. A reading of 18 U.S.C. ยง 2119 shows no distinction between conditional or unconditional intent and therefore does not expressly exclude either species of intent. The court concluded that a reasonable interpretation of the statute is that it covers both conditional and unconditional intent.

The Court also presumed that when Congress enacted the carjacking statute, it was aware of opinions regarding the issue of intent and therefore recognized that "the 'specific intent' to commit a wrongful act may be conditional".

Read more about this topic:  Holloway V. United States

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