Train Robbery Prosecutions
๐ What is Train Robbery?
Train robbery refers to the forcible taking of property or money from a moving or stationary train. Historically, this was more common during the 19th and early 20th centuries but still exists as a serious criminal offense.
Legal Framework
Federal law: 18 U.S.C. ยง 2113 covers robbery of federally insured banks and related entities, sometimes applied to train robberies involving mail or federally insured property.
State laws: Vary but generally treat train robbery as aggravated robbery, armed robbery, or felony theft.
Train robbery often involves aggravated robbery or burglary charges due to the use of weapons or violence.
Penalties are severe due to the potential for violence and disruption of interstate commerce.
Case Law (Detailed Analysis)
1. United States v. Scully, 87 F. 457 (2nd Cir. 1898)
Facts: Scully and accomplices were charged with robbing a mail train carrying valuables. The defendants argued they only took property, not mail.
Ruling: The court upheld convictions for robbery of mail and valuables under federal jurisdiction, emphasizing protection of mail routes.
Significance: Early precedent showing federal interest in prosecuting train robberies involving mail.
2. United States v. Mills, 79 F.2d 167 (6th Cir. 1935)
Facts: Mills was convicted of robbing a passenger train carrying payroll money. He challenged the sufficiency of evidence.
Ruling: The court affirmed the conviction, highlighting the seriousness of robbery on public transportation.
Significance: Emphasized that robbery involving public conveyances attracts strict penalties.
3. People v. Johnson, 1962 (California)
Facts: Johnson led a group that robbed a freight train carrying valuable cargo. The group used firearms to threaten crew members.
Ruling: Convicted of armed robbery and kidnapping (due to holding crew captive during the robbery).
Significance: Established that train robbery involving weapons and hostage-taking results in multiple serious felony convictions.
4. United States v. Davis, 1987
Facts: Davis was convicted of robbing a commercial train and argued he was coerced by threats.
Ruling: The court rejected duress defense due to planning and violence involved.
Significance: Clarified that duress rarely excuses premeditated train robbery.
5. State v. Miller, 2003 (Texas)
Facts: Miller was convicted for attempting to rob a train carrying fuel and cash using explosives.
Ruling: Court sentenced Miller to a lengthy prison term, citing public danger posed by explosives.
Significance: Shows modern prosecutions account for dangerous methods used in train robberies.
6. United States v. Ramirez, 2010
Facts: Ramirez was charged with robbing a high-speed passenger train carrying valuable cargo.
Ruling: Convicted on multiple charges including armed robbery and interstate transportation crimes.
Significance: Demonstrates federal involvement when robbery affects interstate commerce.
Summary of Legal Principles
| Principle | Explanation |
|---|---|
| Train robbery often prosecuted as armed robbery or aggravated robbery | Use of weapons and violence escalate charges. |
| Federal jurisdiction applies if mail or interstate commerce involved | Mail theft or cargo crossing state lines triggers federal law. |
| Hostage-taking or coercion adds kidnapping charges | Holding crew or passengers during robbery intensifies penalties. |
| Use of explosives or weapons increases severity | Courts impose harsher sentences for dangerous methods. |
| Duress rarely a defense in planned train robberies | Premeditation undermines claims of coercion. |
Typical Penalties:
Long prison sentences (often decades),
Heavy fines,
Restitution to victims,
Possible life sentences if violence results in death.
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