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Bell v. United States | 349 U.S. 81 (1955)
A criminal statute may state that a single criminal act is always a single offense, even if it harms multiple victims. Or a statute may state that one act can create multiple offenses, one for each victim. But if a statute doesn’t specify, which rule applies? The United States Supreme Court answered this question in Bell versus United States.
Under the Mann Act, it was illegal for a person to transport any woman or girl across state lines for the purpose of prostitution or something similarly immoral.
Robert Bell drove two women across state lines for immoral purposes and was charged with two violations of the Mann Act. Bell pleaded guilty, admitting that the alleged facts were true. However, the Mann Act didn’t specifically define what was considered a single offense. Bell had driven both women at the same time, in the same vehicle. Bell argued that this meant he’d committed only one offense and could be punished only once.
The district court disagreed and ruled that Bell had committed 2 offenses, one for each transported victim. The district court sentenced Bell to 2 and a half years for each offense. The two sentences ran consecutively for a total sentence of 5 years.
Bell appealed the double punishment. The Sixth Circuit affirmed that each transported person was a separate offense even if the defendant committed only one transportation act. However, several years earlier, the Tenth Circuit had held the opposite, ruling that transporting multiple women in a single trip counted as only one violation of the Mann Act. To resolve the circuit split, the United States Supreme Court agreed to review the case.
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