Bennett v. United States

Background

A woman was indicted under a federal law for causing the transportation of two women, including a woman called Opal Clarke (whose real name was shown to be Jeanette Laplante). She pleaded not guilty, was tried in the District Court for the Southern District of Ohio, convicted, and sentenced to eleven months in the county jail and to pay prosecution costs. The Circuit Court of Appeals affirmed that judgment. The defendant challenged the constitutionality of the statute, but the opinion notes that question had already been decided in a prior case called Hoke v. United States.

Reasoning

The Court focused on several practical questions: whether the indictment’s use of one name while the proof used another harmed the defendant; whether a mismatch about where train tickets were bought mattered; whether charging transportation of two women but proving only one was fatal; and whether jury instructions about treating an accomplice’s testimony were proper. The Court said the indictment and record sufficiently informed the defendant and protected against another prosecution. Minor differences about names and ticket locations did not cause prejudice. Proving one transported person when two were charged was a technical, not a material, defect. The Court also explained that the jury was warned not to convict on uncorroborated accomplice testimony and that assessing any corroboration was for the jury to weigh.

Real world impact

The decision leaves the conviction, sentence, and costs in place. It shows that courts will accept minor variances in charges and proof when those differences do not prejudice the accused, and it upholds standard jury guidance about accomplice testimony.