Simpson v. United States (1978)

On September 8, 1975, the defendants robbed about $40,000 from the East End Branch of the Commercial Bank of Middlesboro at gunpoint.

The District Court ruled that both may apply, as the legislative intention by section 924 (c) was to add an additional punishment.

𝐴𝑠 π‘‘π‘œ πΆπ‘œπ‘’π‘›π‘‘ 𝐼𝐼, π‘‘β„Žπ‘’ 924 (𝑐)(1) π‘π‘œπ‘’π‘›π‘‘, 𝑀𝑒 π‘Ÿπ‘’π‘£π‘’π‘Ÿπ‘ π‘’ π‘Žπ‘›π‘‘ π‘Ÿπ‘’π‘šπ‘Žπ‘›π‘‘ π‘‘β„Žπ‘’ π‘π‘Žπ‘ π‘’ π‘€π‘–π‘‘β„Ž π‘‘π‘–π‘Ÿπ‘’π‘π‘‘π‘–π‘œπ‘›π‘  π‘‘β„Žπ‘Žπ‘‘ πΆπ‘œπ‘’π‘›π‘‘ 𝐼𝐼 𝑏𝑒 π‘‘π‘–π‘ π‘šπ‘–π‘ π‘ π‘’π‘‘," the Court said.

In an 8–1 decision authored by Justice Brennan, the court reversed the lower courts, stating that "several tools of statutory instruction applied to the statutes 'in cases like the present one' -- where the government relied on the same proofs to support the convictions under both statutes -- require the conclusion that Congress cannot be said to have authorized the imposition of the additional penalty of 924 (c) for the commission of bank robbery with firearms already subject to enhanced punishment under 2113 (d)."

The cases were reversed and remanded to the Court of Appeals for proceedings consistent with the ruling.