9.2 Bank Robbery (18 U.S.C. § 2113(b), (c))

            The defendant is charged in [Count _______ of] the indictment with bank robbery in violation of Section 2113 of Title 18 of the United States Code.  For the defendant to be found guilty of that charge, the government must prove each of the following elements beyond a reasonable doubt:

           First, the defendant [[took and carried away with intent to steal or purloin] [received, possessed, concealed, stored, bartered, sold, or disposed of]] [[property] [money] [something of value]] belonging to or in the care, custody, control, management or possession of [specify financial institution];

            Second, what the defendant [took and carried away] [received, possessed, concealed, bartered, sold, or disposed of] had a value [greater than $1000] [of $1000 or less]; [and]

            [Third, the defendant knew that what the defendant received, possessed, concealed, stored, bartered, sold, or disposed of had been stolen; and]

or

            [Third/Fourth], the deposits of [specify financial institution] were then insured by the [Federal Deposit Insurance Corporation] [National Credit Union Administration Board].

Comment

            Use the third element concerning the defendant’s knowledge when the defendant is charged under 18 U.S.C. § 2113(c) and adjust the number of the last element accordingly. 

            See also Instructions 9.1 (Bank Robbery) and 9.3 (Bank Robbery). 

Revised June 2015