In Simpson v. United States, the Supreme Court was asked to decide whether a defendant could be sentenced under two separate statutes for the same crime. The case involved a man who had been convicted of both bank robbery and using a firearm during the commission of that felony, with each conviction carrying its own sentence. The court ruled in favor of Simpson, stating that Congress did not intend for defendants to face punishment under both laws for one act. It held that when two statutory provisions aimed at similar types of wrongdoing overlap in their application to specific conduct, unless there is clear evidence showing contrary legislative intent, it should be presumed that Congress intended only one penalty.

In the dissenting opinion for Simpson v. United States, Justice Blackmun argued that the majority's interpretation of Congress' intent was incorrect. He believed that Congress intended to allow cumulative punishments under both Section 2113(d) and (e). According to him, it is not unusual or unprecedented for a single act to be punishable in more than one way under different provisions of criminal law. Furthermore, he pointed out that there are several instances where courts have upheld multiple punishments for a single act when each statutory provision requires proof of an additional fact which the other does not. In this case, Section 2113(e) requires proof of an additional fact - death resulting from the commission of robbery - which is not required by Section 2113(d). Therefore, he contended that separate punishment should be allowed under both sections.