Mortensen v. United States
Headline: Court limits the Mann Act and reverses convictions of a couple who drove two women on an interstate vacation, ruling such innocent trips cannot be treated as transportation for prostitution.
Holding:
- Restricts prosecutions under the Mann Act when transportation was for innocent purposes.
- Makes it harder to convict people for taking prostitutes on harmless interstate trips.
- Affirms courts will require evidence of intent before applying the law.
Summary
Background
A man and his wife who ran a house of prostitution in Grand Island, Nebraska, took two women who worked for them on a two-week automobile vacation to Yellowstone and Salt Lake City. The women paid their own living expenses; the couple paid transportation. No prostitution occurred during the trip, and the women were free to leave the couple’s employment. After returning, both women resumed prostitution and the couple were charged under the Mann Act for transporting them in interstate commerce for prostitution.
Reasoning
The Court focused on whether the government proved that the interstate trip was undertaken for the purpose of prostitution. After examining the transcript, the Court found no competent evidence that the vacation was designed to effect or facilitate immoral conduct. The justices emphasized that an innocent round trip does not become illegal simply because immoral acts later occurred at the destination. Because intent to use the trip to further prostitution was not shown, the Court reversed the convictions.
Real world impact
The decision narrows the reach of the Mann Act by requiring proof that transportation was undertaken with a primary criminal purpose. Prosecutors cannot rely solely on later immoral acts to infer an illegal purpose for earlier travel. The Court warned against an overly broad application that would punish innocent travel and produce unfair results.
Dissents or concurrances
Four justices disagreed, arguing the record supported an inference that the couple intended the women to resume prostitution on return and would have affirmed the convictions.
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