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Law School Case Brief

Bell v. United States - 349 U.S. 81, 75 S. Ct. 620 (1955)


When Congress leaves to the Judiciary the task of imputing to Congress an undeclared will, the ambiguity should be resolved in favor of lenity. And this not out of any sentimental consideration, or for want of sympathy with the purpose of Congress in proscribing evil or antisocial conduct. It may fairly be said to be a presupposition of American law to resolve doubts in the enforcement of a penal code against the imposition of a harsher punishment.


Bell pleaded guilty to two counts of violating § 2 of the Mann Act, 18 U.S.C.S. § 2421, by allegedly knowingly transporting in interstate commerce two women for an immoral purpose. Because he transported the women on the same trip and in the same vehicle, he claimed that he committed only a single offense and could not be subjected to cumulative punishment. The federal district court rejected that contention and sentenced Bell to consecutive terms. On appeal from the denial of his motion to correct the sentence, the appellate court affirmed, holding that while the act of transportation was a single one, the unlawful purpose necessarily was personal as to each of the women. Thus, it ruled, Bell had committed two separate offenses. The United States Supreme Court granted certiorari review.


Did the appellate court correctly impose the sentence of cumulative punishment for the violation of Mann Act because Bell transported more than one woman for the purpose of prostitution?




The Court reversed the appellate court's judgment finding that when Congress did not fix the punishment for a federal offense clearly and without ambiguity, doubt had to be resolved against turning a single transaction into multiple offenses when there was no more for the Court to go on. Therefore, because Congress had not specified that the simultaneous transportation of multiple women subjected offenders to cumulative punishment, the Court had to resolve the ambiguity in favor of lenity.

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