In the 1982 case Bell v. United States, the Supreme Court ruled on a matter involving federal bank robbery laws. The defendants in this case were charged with robbing two tellers at one bank and argued that they should be convicted of only one offense because both robberies occurred within the same location and during a single event. However, the court disagreed with their interpretation of law. In its decision, it held that each act of taking from a different person or place constitutes a separate offense under federal law for bank robbery even if all acts are part of one criminal episode or transaction. Therefore, multiple convictions stemming from such an incident do not violate double jeopardy protections provided by Fifth Amendment to U.S Constitution.

In the dissenting opinion for Bell v. United States, Justice Brennan disagreed with the majority's interpretation of 18 U.S.C. § 2113(a) and (d). He argued that Congress intended to punish bank robbers who assault or put lives in jeopardy more severely than those who do not, regardless of whether they succeed in stealing any money. The majority’s decision to interpret “any property” as including a person’s control over their own body was seen by Brennan as an unwarranted expansion of federal jurisdiction into areas traditionally reserved for state law enforcement. Furthermore, he contended that this broad interpretation could potentially lead to absurd results such as applying federal robbery statutes to pickpocketing incidents if physical force is used during the act. In his view, it would be better suited for these cases to be handled under state laws rather than expanding federal jurisdiction unnecessarily.