## Facts

- Three defendants (F. Drew Caminetti, Maury I. Diggs, and L. T. Hays) were prosecuted under § 2 of the White Slave Traffic Act of 1910 (Mann Act) for knowingly transporting women across state lines “for the purpose of prostitution or debauchery, or for any other immoral purpose.”
- The prosecutions involved consensual, noncommercial sexual relationships; the women were transported to live as mistresses/concubines rather than for commercial prostitution.
- Caminetti was indicted in the Northern District of California on four counts, convicted on one, and sentenced to 18 months’ imprisonment and a fine.
- Diggs was indicted in the same district on six counts, convicted on four, and sentenced to two years’ imprisonment and a fine.
- Hays was indicted in the Eastern District of Oklahoma for transporting a female under 18 for immoral purposes, convicted on two counts, and sentenced to 18 months’ imprisonment.
- The Ninth Circuit affirmed the Caminetti/Diggs convictions, and the Eighth Circuit affirmed Hays’s conviction.
- The Supreme Court granted certiorari and considered the cases together.

## Issues

1. Whether the Mann Act phrase “or for any other immoral purpose” reaches interstate transportation for consensual, noncommercial sexual relationships (e.g., to make a woman a mistress/concubine), or is limited to commercial prostitution and “white slavery.”
2. Whether applying the Mann Act to noncommercial sexual conduct exceeds Congress’s power to regulate interstate commerce.
3. Whether a jury may draw adverse inferences from a defendant’s failure, after choosing to testify, to deny or explain incriminating circumstances already in evidence.
4. Whether the failure to give a cautionary instruction about accomplice testimony requires reversal.

## Decision

- The Supreme Court affirmed the convictions.
- The Court held that “any other immoral purpose” includes noncommercial sexual conduct such as transporting a woman to be a mistress or concubine; pecuniary gain is not an element.
- The Court held the statute constitutional as applied, because Congress may regulate interstate transportation to prevent immoral and injurious uses of the channels of commerce.
- The Court upheld the challenged instruction permitting the jury to infer meaning from a testifying defendant’s omission to deny or explain incriminating evidence, distinguishing it from commentary on a defendant’s refusal to testify.
- The Court held that while cautioning juries about accomplice testimony is preferable, the failure to do so is not reversible error.
- A dissent argued the Act should be read in context as targeting commercialized vice and not private, consensual affairs.

## Legal Principles

- When statutory language is plain and does not produce absurd or impracticable results, courts apply the text as written rather than narrowing it through interpretive aids.
- A statute’s title or popular name cannot override clear operative provisions.
- Legislative history is generally consulted only where the statutory text is doubtful or ambiguous.
- Congress is presumed to legislate with awareness of prior judicial constructions when it uses identical language in a similar context.
- Congress may prohibit interstate transportation undertaken for immoral purposes to keep the channels of interstate commerce free from immoral and injurious uses.
- If a defendant voluntarily testifies, the jury may consider the defendant’s failure to deny or explain incriminating circumstances in evidence, consistent with the Fifth Amendment.
- Omission of a specific accomplice-testimony caution instruction, without more, does not require reversal.

## Conclusion

The Court read the Mann Act’s “any other immoral purpose” language according to its ordinary meaning, holding it covers interstate travel arranged for noncommercial sexual relationships such as concubinage, upheld the statute as a valid exercise of the commerce power, and sustained jury instructions allowing inferences from a testifying defendant’s unexplained incriminating evidence and declining to mandate an accomplice caution instruction.


Caminetti v. United States, 242 U.S. 470 (1917)