Holloway v. United States

SCOTUSCase
Litigants=Holloway v. United States
ArgueDate=November 9
ArgueYear=1998
DecideDate=March 2
DecideYear=1999
FullName=Francois Holloway, a.k.a. Abdu Ali v. United States
USVol=526
USPage=1
Citation=
Subsequent=
Holding=The federal carjacking law does apply to carjacking crimes committed by defendants with the "conditional intent" of harming drivers who resist the highjacker.
SCOTUS=1994-2005
Majority=Stevens
JoinMajority=Kennedy, Souter, Ginsburg, Breyer, Rehnquist, O'Connor
Dissent=Scalia
JoinDissent= Thomas
Dissent2=
LawsApplied=ussc|526|1|1999

"Holloway v. United States", ussc|526|1|1999, 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.cite web
author=
year=
url=http://www.oyez.org/cases/1990-1999/1998/1998_97_7164/
title=Holloway v. United States
publisher=oyez.ort
accessdate=2008-02-14]

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. [cite web
author=
year=
url=http://journals.cambridge.org/action/displayAbstract;jsessionid=7D0DB2EF0D7143B0BE09100601350D2B.tomcat1?fromPage=online&aid=265325#fn1
title=Conditional Intent and Mens Rea
publisher=Cambridge Journal
accessdate=2008-02-15]

Facts of case

Francois Holloway, a.k.a. Abdu Ali, was charged with three counts of carjacking as defined by usc|18|2119. 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.cite web
author=
year=1998
url=http://sol.lp.findlaw.com/1998/holloway.html
title=Carjacking - Required Intent
publisher=findlaw.com
accessdate=2008-02-16] However, he testified he would have used his gun if it was necessary to obtain the car. The jury was instructed 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.

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 prosecution 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.cite web
author=
year=
url=http://law.onecle.com/ussc/526/526us01.html
title=Holloway v. United States , 526 U.S. 1 (1999)
publisher=law,onecle.com
accessdate=2008-02-15] 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 usc|18|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. [cite web
author=Chris Norborg
year=2000
url=http://links.jstor.org/sici?sici=0091-4169%28200021%2990%3A3%3C985%3ACITKIE%3E2.0.CO%3B2-K&size=LARGE&origin=JSTOR-enlargePage
title=Conditional Intent to Kill Is Enough for Federal Carjacking Conviction
publisher=Justor
accessdate=2008-02-15]

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

usc|18|2119 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 government 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. [cite web
author=
year=
url=http://www.usdoj.gov/osg/briefs/1997/3mer/2mer/97-7164.mer.html
title= Francois Holloway, AKA Abdu Ali, Petitioner v. United States of American - Brief for the United States
publisher=usdoj.gov
accessdate=2008-02-15] 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. [cite web
author=
year=
url=http://ca10.washburnlaw.edu/cases/2005/08/04-2216.htm
title=Appeal from the United States District Court for the District of New Mexico
publisher=washburnlaw.edu
accessdate=2008-02-15]

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. [cite web
author=
year=
url=http://law.onecle.com/ussc/526/526us02.html
title=Holloway v. United States
publisher=law.onecle
accessdate=2008-02-15]

ee also

*List of United States Supreme Court cases, volume 526

Footnotes

External links

* [http://supreme.justia.com/us/526/1/case.html Holloway aka Ali v. United States 526 U.S. 1 - Opinion]
* [http://www.law.cornell.edu/supct/html/97-7164.ZO.html Francois Holloway, aka Abdu Ali, Petitioner v. United States]
* [http://www.law.emory.edu/11circuit/may2002/01-13607.opn.html Eleventh Circuit Opinion]
* [http://law.shu.edu/journals/lawreview/library/vol_30/30_2/peckham.pdf Holloway V. United States: The United States Supreme Court Examines "conditional intent" in the Anti Car Theft Act of 1992]