Carter pleaded not guilty on the grounds that he had not used any force, violence, or intimidation to deprive the bank of its money.

The District Court denied the motion and the jury returned a guilty verdict on the count of robbery.

Carter argued that Congress intended for § 2113(b) to be a lesser crime of § 2113(a) because § 2113(c) applied only whenever § 2113(b) was violated and the Court rejected this argument.

The Court declined to apply a less rigid test to determine whether § 2113(b) was a lesser offense, citing its prior holding in Schmuck v. United States.

The Carter opinion showed that the Court was willing to abandon common law interpretation principles for some federal statutes or statutory provisions by asserting that "a 'cluster of ideas' from the common law should be imported into statutory text only when Congress employs a common-law term".