Bell v. United States
Citation and Court
349 U.S. 81 (1955) — Supreme Court of the United States
Facts
Bell transported two women across state lines for illegal purposes in a single trip in the same car. He was convicted on two counts under the Mann Act (one for each woman). The question was whether transporting two women simultaneously constituted one violation or two.
Issue
Whether transporting two women simultaneously in a single trip constitutes one offense or two separate violations of the Mann Act.
Holding
Transporting two women in one trip constitutes a single offense, not two. Where a statute is ambiguous as to the unit of prosecution, the rule of lenity requires resolving the ambiguity in the defendant’s favor.
Rule / Doctrine
The rule of lenity: when a criminal statute’s meaning is ambiguous and Congress has not plainly expressed intent to create multiple punishments for a single act, courts construe the statute in favor of the defendant. The principle reflects the constitutional requirement that criminal statutes provide fair notice and that penal consequences not be casually multiplied.
Significance
A canonical statement of the rule of lenity and its application to unit-of-prosecution questions. Frequently cited for the proposition that statutory ambiguity in criminal law must be resolved in favor of the accused.