In the 1935 case Gooch v. United States, the Supreme Court ruled on whether a defendant could be convicted of both conspiracy to commit a crime and the substantive offense itself under federal law. The defendants were charged with conspiring to rob mail carriers and robbing mail carriers - two separate offenses under different sections of the same statute. They argued that they should not have been indicted for both crimes because they are essentially identical in nature. However, the court held that each charge required proof of a fact which other did not; thus, each constituted a separate offense for which punishment could separately be imposed. Therefore, it was permissible to convict them on both counts.

In the dissenting opinion for Gooch v. United States, Justice Stone argued that the majority's interpretation of the Lindbergh Law was incorrect. He contended that Congress intended to punish kidnappers who transported their victims across state lines with a higher degree of severity than those who did not engage in interstate transportation. According to him, this intention is clear from both the language and legislative history of the law itself. Therefore, he disagreed with the majority's decision to uphold Gooch's conviction under this law even though there was no evidence proving he had taken his victim across state lines during his crime. In essence, Justice Stone believed that by ignoring these key aspects of congressional intent when interpreting and applying federal laws like this one, courts risk undermining their legitimacy and effectiveness.