Facts
- Robert Cecil Bell transported two women across state lines in a single trip in the same vehicle for prohibited purposes under the Mann Act (18 U.S.C. § 2421).
- Bell pleaded guilty to two counts, each count tied to one woman transported during the same trip.
- At sentencing, Bell argued the conduct constituted one offense because there was only one act of transportation.
- The district court imposed consecutive sentences on the two counts.
- The Sixth Circuit affirmed after denial of a motion to correct sentence, concluding two separate offenses occurred because the unlawful purpose related separately to each woman.
- The Supreme Court granted review to resolve disagreement among circuits on whether one trip transporting multiple women supports multiple Mann Act offenses.
Issues
- Whether a single interstate transportation trip involving more than one woman constitutes multiple Mann Act offenses or a single offense.
- How to determine the “allowable unit of prosecution” when a federal criminal statute is ambiguous.
- Whether ambiguity about cumulative punishment under the Mann Act must be resolved in favor of the defendant.
Decision
- The Supreme Court reversed.
- The Court held Bell committed only one offense under the Mann Act based on a single act of transportation.
- The Court concluded Congress did not clearly authorize cumulative punishment for each woman transported simultaneously in one trip.
- Because the statute was ambiguous as to the unit of prosecution, the Court applied the rule of lenity and rejected consecutive sentences on the two counts.
Legal Principles
- The “unit of prosecution” for a federal crime depends on what Congress has clearly made punishable as one offense versus multiple offenses.
- When statutory text reasonably supports competing interpretations about whether one transaction may be split into multiple offenses, courts resolve doubt against multiplying offenses and punishments.
- Under the Mann Act, simultaneous transportation of multiple women in a single interstate trip is treated as one offense absent clear congressional authorization for cumulative punishment.
Conclusion
The Court limited cumulative sentencing under the Mann Act by holding that one interstate trip transporting two women is a single punishable offense, and that statutory ambiguity about the unit of prosecution requires application of the rule of lenity against multiple punishments.