In Simpson v. U-S. (435 U..S. 6), the Supreme Court held that a defendant convicted of an aggravated bank robbery under 10 U'-S.C.A., § 2113(d) could not also be convicted under the general statute of § 924(c) (the same proofs being required) for his conduct growing out of a single transaction.

Was it permissible for the lower court(s) to ignore applying the Court's Simpson precedent under its assumption that Congress overrode the Simpson precedent when it amended 18 U.S.C.A. § 924(c) in 1984?

Whether the lower court improperly disregarded Simpson v. U.S. precedent by assuming Congressional amendment of 18 U.S.C.A. § 924(c) in 1984 overrode prior judicial interpretation