Holloway v. United States
Encyclopedia
Holloway v. United States, , is a United States Supreme Court
case in which the court addressed the issue of whether the federal carjacking
law applies to crimes committed with the "conditional intent" of harming drivers who refuse a carjacker's demands.
Federal law considers the act of hijacking an automobile
as carjacking
only if the hijacker did so with the intent to kill or inflict serious bodily harm to the driver of the car.
that the requisite intent under law may be conditional and the government would have satisfied the condition of intent if it proved that the defendant intended to cause death or bodily harm if the drivers refused to comply. Thereafter, the jury found Holloway guilty. The Court of Appeals affirmed the conviction, holding that a conditional intent to harm was within the bounds of a reasonable interpretation of the legislative purpose behind the federal carjacking law.
The Supreme Court granted Holloway's writ
of certiorari
.
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 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".
prosecution, to establish a carjacking charge, must prove that a defendant acted with the "intent to cause" death
or harm. There is no requirement that this intent had to have actually resulted to complete the elements for the carjacking offense. Rather, the substantive harm that must result is the taking of a motor vehicle
, by force and violence or by intimidation, from the person or in the presence of the victim. Therefore, the intent necessary to commit a carjacking is a conditional intent. The defendant does not have to indicate a desire to injure the victim if the jury can infer that, if the victim had refused to give up his car, the carjacker would have harmed him.
The Court's conclusion is also supported by another consideration. The defendant's interpretation of the statute would remove from the statute any coverage of the conduct that Congress specifically intended to prohibit. It can be assumed that Congress was familiar with the leading opinions and court cases regarding the need for allowing specific intent to commit a wrongful act to be conditional under certain conditions.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case in which the court addressed the issue of whether the federal carjacking
Carjacking
Carjacking is a form of hijacking, where the crime is of stealing a motor vehicle and so also armed assault when the vehicle is occupied. Historically, such as in the rash of semi-trailer truck hijackings during the 1960s, the general term hijacking was used for that type of vehicle abduction,...
law applies to crimes committed with the "conditional intent" of harming drivers who refuse a carjacker's demands.
Federal law considers the act of hijacking an automobile
Automobile
An automobile, autocar, motor car or car is a wheeled motor vehicle used for transporting passengers, which also carries its own engine or motor...
as carjacking
Carjacking
Carjacking is a form of hijacking, where the crime is of stealing a motor vehicle and so also armed assault when the vehicle is occupied. Historically, such as in the rash of semi-trailer truck hijackings during the 1960s, the general term hijacking was used for that type of vehicle abduction,...
only if the hijacker did so with the intent to kill or inflict serious bodily harm to the driver of the car.
Facts of case
Francois Holloway, a.k.a. Abdu Ali, was charged with three counts of carjacking as defined by . Holloway's co-defendant and prosecuting witness testified that, although he pointed a gun at the driver and threatened to shoot him unless the driver relinquished the car and keys, the intent was to steal the vehicles and not to harm the occupants. However, he testified he would have used his gun if it was necessary to obtain the car. The jury was instructedJury instructions
Jury instructions are the set of legal rules that jurors should follow when the jury is deciding a civil or criminal case. Jury instructions are given to the jury by the jury instructor, who usually reads them aloud to the jury...
that the requisite intent under law may be conditional and the government would have satisfied the condition of intent if it proved that the defendant intended to cause death or bodily harm if the drivers refused to comply. Thereafter, the jury found Holloway guilty. The Court of Appeals affirmed the conviction, holding that a conditional intent to harm was within the bounds of a reasonable interpretation of the legislative purpose behind the federal carjacking law.
The Supreme Court granted Holloway's writ
Writ
In common law, a writ is a formal written order issued by a body with administrative or judicial jurisdiction; in modern usage, this body is generally a court...
of certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
.
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 prosintent (law)|ecution 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
Mens rea
Mens rea is Latin for "guilty mind". In criminal law, it is viewed as one of the necessary elements of a crime. The standard common law test of criminal liability is usually expressed in the Latin phrase, actus non facit reum nisi mens sit rea, which means "the act does not make a person guilty...
is directed at the defendant's state of mind at that moment in time when he hijacks the vehicle. A reading of 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".
Discussion
requires intent to cause a result, but actual occurrence of the result is not an element of the offense of carjacking. It is clear that the governmentGovernment
Government refers to the legislators, administrators, and arbitrators in the administrative bureaucracy who control a state at a given time, and to the system of government by which they are organized...
prosecution, to establish a carjacking charge, must prove that a defendant acted with the "intent to cause" death
Death
Death is the permanent termination of the biological functions that sustain a living organism. Phenomena which commonly bring about death include old age, predation, malnutrition, disease, and accidents or trauma resulting in terminal injury....
or harm. There is no requirement that this intent had to have actually resulted to complete the elements for the carjacking offense. Rather, the substantive harm that must result is the taking of a motor vehicle
Motor vehicle
A motor vehicle or road vehicle is a self-propelled wheeled vehicle that does not operate on rails, such as trains or trolleys. The vehicle propulsion is provided by an engine or motor, usually by an internal combustion engine, or an electric motor, or some combination of the two, such as hybrid...
, by force and violence or by intimidation, from the person or in the presence of the victim. Therefore, the intent necessary to commit a carjacking is a conditional intent. The defendant does not have to indicate a desire to injure the victim if the jury can infer that, if the victim had refused to give up his car, the carjacker would have harmed him.
The Court's conclusion is also supported by another consideration. The defendant's interpretation of the statute would remove from the statute any coverage of the conduct that Congress specifically intended to prohibit. It can be assumed that Congress was familiar with the leading opinions and court cases regarding the need for allowing specific intent to commit a wrongful act to be conditional under certain conditions.
See also
- List of United States Supreme Court cases, volume 526
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume