Derrick Grant v. United States
Environmental SocialSecurity Securities Immigration
Section 111 of Title 18 of the United States Code prohibits assaulting any person "designated in section 1114 of this title." Section § 1114 designates "any officer or employee of the United States or of any agency of the United States Government . . . or any person assisting such an officer or employee in the performance of such duties" as qualifying. Here, the defendant punched an employee of a company that operates a private prison and was convicted of assault under 18 U.S.C. § 111. The courts below identified no officer or employee being assisted. Instead, the courts found that that the private employee was assisting the Marshals Service, a federal agency. But an "agency" is not "an officer or employee." Was the private prison's employee "assisting such an officer or employee" such that the employee was a covered person under § 1114?
Whether a private prison employee assisting federal marshals is covered under 18 U.S.C. § 1114