Supreme Court of the United States · 1955 · Evidence
EvidenceMann Actunit of prosecutionrule of lenityMann Act18 U.S.C. § 2421unit of prosecutionallowable unit of prosecution
Facts
Petitioner pleaded guilty to two counts under the Mann Act, with each count referring to a different woman. He transported both women on the same trip and in the same vehicle. He argued that this conduct constituted only one offense, so cumulative punishment on two counts was improper. The lower courts rejected that argument and imposed and upheld consecutive sentences.
Issue
When a defendant simultaneously transports two women on the same interstate trip in the same vehicle for an immoral purpose under the Mann Act, does that conduct constitute one offense or two for purposes of punishment?
Rule
If Congress does not clearly and unambiguously define the unit of prosecution in a federal penal statute, ambiguity must be resolved in favor of lenity. In such circumstances, courts should resolve doubt against turning a single transaction into multiple offenses.
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10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Tulsa, Nolan Price drove two adult passengers from Oklahoma to Kansas in one van during a single continuous overnight trip. Federal prosecutors charged him under a transportation-for-illicit-purpose statute that punishes anyone who knowingly transports "any person" in interstate commerce for a prohibited purpose, but the statute does not otherwise define the unit of prosecution.
If the statute's text and structure do not clearly specify whether each passenger creates a separate offense, what is the strongest argument against imposing two consecutive sentences?
Explanation. The controlling rule is that the question is what Congress made the allowable unit of prosecution. If Congress has not clearly and without ambiguity fixed separate punishment, doubt is resolved against turning a single transaction into multiple offenses. The majority specifically treated a single interstate transportation event as one offense where the statute did not clearly authorize cumulative punishment per transported person.