Holloway v. United States
526 U.S. 1 · Supreme Court of the United States · 1999
Facts
Petitioner and an armed accomplice committed multiple carjackings. They identified desired cars, followed them until parked, and then the accomplice approached the driver with a gun, threatening to shoot unless the keys were handed over. The accomplice testified their plan was to steal cars without harming victims, but he would have used his gun if drivers resisted. When one victim hesitated, petitioner punched him, but no other actual violence occurred.
Procedural history
A jury found the petitioner guilty, and the District Judge instructed the jury that conditional intent was sufficient. The District Judge denied the petitioner's post-verdict motion for a new trial, which argued the instruction was inconsistent with the statute. The Court of Appeals affirmed the District Court's decision. The Supreme Court granted certiorari to resolve a conflict with a Ninth Circuit decision.
Issue
Does the federal carjacking statute's phrase "with the intent to cause death or serious bodily harm" require proof of an unconditional intent to kill or harm, or merely an intent to kill or harm if necessary to effect a carjacking?
Holding
The Court held that the intent requirement of the carjacking statute is satisfied when the government proves the defendant possessed the intent to seriously harm or kill the driver if necessary to steal the car. The Court affirmed the judgment of the Court of Appeals.
Rule
The federal carjacking statute, 18 U.S.C. §2119, which criminalizes carjacking "with the intent to cause death or serious bodily harm," encompasses both conditional and unconditional intent to harm. This means the intent element is satisfied if the defendant intended to cause death or serious bodily harm only if necessary to complete the carjacking. This interpretation aligns with a commonsense reading of the statute, its broad deterrent purpose, and established legal principles recognizing conditional intent in criminal law, as exemplified by cases like People v. Connors and the Model Penal Code.
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