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Criminal Resource Manual

1466. Robbery Or Theft Of Mail, Money Or Property Of The U.S. -- 18 U.S.C. 2114

Section 2114 of Title 18 prohibits assaulting with intent to rob "any person having lawful charge, control, or custody of any mail matter or of any money or other property of the United States..." and the robbing of such a person. In Garcia v. United States, 469 U.S. 70 (1984), the Supreme Court held that the legislative history of 18 U.S.C. § 2114 shows no intent by Congress to limit the statute to postal crimes and that 18 U.S.C. § 2114 penalized assaults or robberies of anyone who is a custodian of "any money or other property of the United States." In light of the holding in Garcia, United States Attorneys may now seek indictments of persons who rob United States officials although no Postal Service nexus exists.

[cited in USAM 9-64.200]