Cleveland v. United States

1946-12-16

Headline: Court affirms convictions for moving plural wives across state lines, ruling the federal Mann Act covers polygamy and allowing prosecutions even when defendants claim religious motive, affecting members of polygamous sects.

Holding: The Court held that the Mann Act’s phrase “any other immoral purpose” includes polygamous practices, so transporting plural wives interstate can be prosecuted and religious belief is not a defense.

Real World Impact:

Allows federal prosecutions for transporting plural wives across state lines under the Mann Act.
Rejects religious belief as a defense to such prosecutions.
Affirms federal reach over interstate movement for practices deemed ‘immoral’.

Topics: polygamy, interstate travel law, federal criminal law, religion and law

Summary

Background

Members of a polygamous religious sect (called Fundamentalists) were tried for transporting their plural wives across state lines so they could live together or to help others do so. The men were convicted in bench trials under the Mann Act, which outlaws transporting a woman “for the purpose of prostitution or debauchery, or for any other immoral purpose.” The convictions were affirmed on appeal and the case reached the Court to resolve how broadly the statute reaches.

Reasoning

The Court asked whether “any other immoral purpose” in the Mann Act includes polygamous practices and whether religious belief excuses the conduct. Relying on earlier cases that read the law to reach concubinage and similar acts, the majority concluded the Act is not limited to commercialized sex and covers polygamous arrangements. The Court found evidence that interstate movement was motivated by a desire to cohabit in plural marriages, and it held that a claimed religious motive does not excuse conduct that the statute condemns.

Real world impact

The decision means federal prosecutors may use the Mann Act to charge people who move plural wives across state lines to establish or maintain polygamous households. Those who act out of religious belief cannot avoid prosecution under this statute. The ruling preserves past interpretations of the law and leaves questions about Congress or the full Court overturning those precedents for another time.

Dissents or concurrances

One Justice concurred in the outcome but criticized the earlier precedent; another Justice dissented, arguing the statute targets the "white slave" trade and should not be stretched to cover polygamy, and two Justices would have reversed.