United States v. Park, No. 11-3973 (6th Cir. 2012)
Annotate this CaseIn 2003, in the getaway from an armed bank robbery, Parks crashed his car while fleeing police and killed his passenger, a co-conspirator. Parks pled guilty to bank robbery resulting in the killing of another (18 U.S.C. 2113(e)) and agreed to a sentence of 372 months, but reserved his right to appeal whether a 2113(e) violation requires mens rea. The Seventh Circuit affirmed the conviction, but remanded with respect to the mandatory minimum penalty. On remand, the district court held that Congress, in amending 2113(e) when it enacted the Federal Death Penalty Act of 1994, intended to increase the mandatory minimum sentence from 10 years to life imprisonment or death in all 2113(e) cases where death results. The district court also concluded that it was bound by the prior plea agreement. Parks moved to withdraw his plea and to declare 2113(e) unconstitutional. The district court concluded that the arguments were beyond the scope of remand and re-sentenced Parks to 372 months of imprisonment. The Seventh Circuit affirmed. The district court correctly applied the Circuit Court’s mandate and found that the statute requires a mandatory minimum sentence of life, even though Parks arranged for a plea agreement of less than life.
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