In the 1972 case of Erlenbaugh et al. v. United States, the Supreme Court ruled in favor of the U.S government, upholding convictions under two federal statutes: The Federal Bank Robbery Act and The Travel Act. Defendants argued that their actions did not violate both laws simultaneously as they were charged with robbing a bank (violating Federal Bank Robbery Act) and then traveling across state lines (violating The Travel Act). They contended that Congress intended for each law to be exclusive, thus one act could not constitute violation of both laws. However, the court disagreed stating there was no evidence suggesting Congressional intent for exclusivity between these two acts. Instead, it found that these statutes are designed to combat different types of criminal activities and can coexist without conflict; hence simultaneous violations were possible.

In the dissenting opinion for Erlenbaugh et al. v. United States, it was argued that the majority's interpretation of the Federal Bank Robbery Act (FBRA) was too broad and not in line with Congressional intent. The dissenters believed that Congress intended to punish only those who directly participated in bank robberies or related offenses, not individuals involved indirectly such as through conspiracy charges. They pointed out that other federal laws specifically include conspiracy provisions when intended by lawmakers, but FBRA does not contain such language explicitly including conspiracies within its scope. Therefore, they disagreed with applying a broader reading to this law than what is written in its text and supported by legislative history.