Bell v. United States
United States Supreme Court
462 U.S. 356 (1983)
A Cincinnati man mailed a $10,000 check to Dade Federal Savings & Loan for deposit into his account, but the bank employee never received it. Nelson Bell (defendant) opened his own account at a different Dade Federal branch using a false address, birthdate, and Social Security number, then deposited the misdirected $10,000 check, whose endorsement had been altered to show his account number, into that account. After a 20-day hold expired, Bell withdrew the funds and closed the account. He was charged and convicted under 18 U.S.C. Section 2113(b), the Federal Bank Robbery Act's theft provision, and appealed.
Whether the Federal Bank Robbery Act's provision criminalizing the taking of bank property, 18 U.S.C. Section 2113(b), applies only to conduct matching common-law larceny.