On review for plain error (because the issue was not raised by the parties below), the Court of Appeals determined that there was no proof that the credit union robbed was covered by federal insurance, currently in force, from the National Credit Union Administration Board. As this is an essential element of the bank robbery offense, the court reversed appellant’s robbery conviction, as well as his second conviction for a crime of violence which could be prosecuted in a federal court. Because the federal jurisdictional element was not proved in either offense, both counts were reversed.
Case Summaries