Bell v. United States
United States Supreme Court
349 U.S. 81 (1955)
The government charged Bell (defendant) with two counts of violating the Mann Act for transporting two women in interstate commerce for prostitution, even though he transported both women in the same vehicle on the same single trip. Bell pled guilty but argued at sentencing that transporting two women simultaneously in one trip was only a single offense, not two. The district court disagreed and imposed consecutive sentences on both counts; the court of appeals affirmed, and the Supreme Court granted certiorari.
Whether, under the lenity principle of statutory construction, ambiguity in a criminal statute about whether transporting multiple victims in a single transaction creates multiple punishable offenses must be resolved in the defendant's favor.