In the United States v. Holte case of 1914, the Supreme Court ruled that a woman could be prosecuted under the Mann Act for assisting in her own transportation across state lines for immoral purposes. The defendant, Ruth Holte, was accused of conspiring with a man to violate this federal law (also known as White-Slave Traffic Act), which made it illegal to transport women across state borders "for any immoral purpose". She argued that as a woman she couldn't be charged under this act because its language specifically targeted men who transported women. However, the court disagreed and held that while the primary intent of Congress may have been to target male offenders, there was no explicit exemption for females in aiding or abetting such an offense. Therefore, even though she was not directly involved in her own transportation but had conspired with another person who did so violated Mann Act according to majority opinion delivered by Justice Mahlon Pitney.

In the dissenting opinion for United States v. Holte, Justice Oliver Wendell Holmes Jr., joined by Justice Charles Evans Hughes, argued that the Mann Act was not intended to punish women who willingly participated in illicit sexual activities across state lines. They contended that Congress aimed to penalize those who coerced or deceived women into such acts, rather than punishing the women themselves. The majority's interpretation of the law as applicable to willing participants would mean any woman crossing a state line for immoral purposes could be prosecuted under federal law - an outcome they believed Congress did not intend when drafting this legislation. Furthermore, they asserted that if Congress had meant for willing participants to be punishable under this act, it would have explicitly stated so within its text.