Criminal Law, Pages 114–115

Bell v. United States

1955

Facts:

Defendant pleaded guilty to two counts of transporting women for prostitution, debauchery, or another immoral purpose, in violation of the Mann Act; but these two women were transported in the same trip in a single vehicle.

Defendant's Argument:

Defendant only made one trip, so he only made a single offense and could only be penalized for that count.

Procedural History:

  • District court rejected defendant's argument and sentenced him to two consecutive terms of two years and six months per count.

  • Court of appeals affirmed.

Issue:

Did the Mann Act make the simultaneous transportation of multiple women liable to cumulative punishment for each woman transported?

Rule:

Reasoning:

The statute does not say which interpretation is correct. While either is plausible, if Congress intended them to be cumulative, it could have said so. When it does not, the ambiguity should be resolved in favor of lenity.

Holding:

It is ambiguous and thus the lighter penalty should be applied. Reversed.

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