In Brooks v. United States (1948), the Supreme Court ruled that a person could be convicted of robbery even if they did not physically take property from another individual, but instead used force or intimidation to compel the victim to hand over their possessions. The case involved two brothers who had been convicted of robbing a post office employee by forcing him at gunpoint to give them money orders which they later cashed in. They appealed on grounds that since they didn't directly take the money orders from the employee's possession, it wasn't technically robbery under federal law. However, Justice Stanley Reed delivered an unanimous decision stating that compelling someone through fear or violence to surrender their property is still considered taking "from his person" and thus constitutes as robbery.

In the dissenting opinion for Brooks v. United States, Justice Jackson argued that the majority's decision to allow a civilian employee of the Army to sue under Federal Tort Claims Act (FTCA) was an overreach and misinterpretation of Congressional intent. He contended that Congress did not intend for FTCA to apply in situations where military personnel were injured while on active duty or due to their service-related activities. Instead, he believed that such cases should be handled through established military compensation systems which are designed specifically for these types of injuries and losses. Furthermore, he warned against potential negative implications this ruling could have on future litigation involving servicemen injured during wartime or in foreign countries as it might encourage lawsuits against the government based on decisions made during combat operations.