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The Federal Bank Robbery Act: Why The Current Split Involving The Use Of Force Requirement For Attempted Bank Robbery Is Really An Exception, Paul Piaskoski
The Federal Bank Robbery Act: Why The Current Split Involving The Use Of Force Requirement For Attempted Bank Robbery Is Really An Exception, Paul Piaskoski
Journal of Criminal Law and Criminology
The Federal Bank Robbery Act had been on the books for seventy years by the time the federal appellate courts began to openly quarrel about the necessary elements of attempted bank robbery under the first paragraph of the Act, 18 U.S.C. § 2113(a). Specifically, the circuits disagree as to whether proof of actual force is required to sustain a conviction of attempted bank robbery, or if attempted force is sufficient for a conviction. Legal scholars have repeatedly framed this split in authority as a consequence of competing methods of statutory interpretation. In this Comment, however, I argue that it is …