In Whitfield v. United States (2014), the Supreme Court unanimously ruled that under federal law, a bank robber who forces someone to accompany him for any distance during the commission of a crime or in fleeing it is subject to an enhanced penalty. The case involved Larry Whitfield, who had broken into Mary Parnell's home while fleeing police after a failed bank robbery attempt. Although he only forced her to move from one room to another within her own house, and she died of a heart attack shortly thereafter due to stress caused by his intrusion, the court held that this movement constituted "forced accompaniment" as defined by 18 U.S.C §2113(e). This ruling clarified that even minor movements can trigger additional penalties if they are done against someone’s will and in conjunction with certain crimes.

In the dissenting opinion for Whitfield v. United States, Justice Scalia argued that the majority's interpretation of 18 U.S.C. §2113(e) was incorrect and overly broad. He contended that the statute should be read to require a significant degree of force in order to qualify as "forcing" someone to accompany another person during a bank robbery or attempted bank robbery. According to him, merely causing someone to move from one room within their home into another does not meet this standard and thus should not trigger an additional penalty under federal law. Furthermore, he criticized the majority for relying on dictionary definitions rather than considering how Congress intended for these terms to be understood when it enacted this legislation in 1934.