In the Ladner v. United States case of 1957, petitioner Henry Ladner was convicted under a federal statute for injuring two federal officers with a single shotgun blast during their attempt to arrest him. The issue at hand was whether one discharge of a firearm that injured multiple officers constituted one offense or several under the law. The Supreme Court held that Congress intended to punish acts of violence against individual officers separately, even if they resulted from a single act by the defendant. However, due to lack of clarity in jury instructions regarding this point and uncertainty about whether the jury based its verdict on an erroneous understanding, it could not be determined beyond reasonable doubt that Ladner had been found guilty as charged - i.e., wounding each officer in separate offenses rather than in just one offense (which would have been legally incorrect). Therefore, his conviction couldn't stand and he was entitled to another trial where clear instructions should be given.

In the dissenting opinion for Ladner v. United States, Justice Harlan argued that the majority's interpretation of "any person" in 18 U.S.C. § 254 (now § 111) was too narrow and not consistent with Congress' intent when drafting the law. He believed that if a single act of violence resulted in injuries to multiple federal officers, it should be treated as separate offenses under this statute because each officer represents a distinct individual interest protected by law. The majority’s decision to treat such an incident as one offense could potentially undermine respect for federal officers by minimizing punishment for violent acts against them. Furthermore, he criticized the majority's reliance on legislative history instead of focusing on statutory language itself which clearly indicates that each injured officer constitutes a separate victim and hence, a separate offense.