In the 1970 case of Williams v. United States, the Supreme Court ruled on whether a bank robbery could be considered as two separate offenses under different sections of the same statute. The defendant, Williams, was charged with both entering a bank with intent to commit a felony and robbing that bank - each charge carrying its own punishment. He argued that this constituted double jeopardy or being tried twice for the same crime which is prohibited by the Fifth Amendment. However, in an 8-1 decision led by Justice Hugo Black, it was held that these were distinct offenses despite arising from one act because each required proof of a fact not necessary for proving the other; therefore they did not violate double jeopardy principles.

In the dissenting opinion for Williams v. United States, Justice Harlan argued that the majority had misinterpreted Section 641 of Title 18 in relation to theft from interstate shipment. He believed that this section was intended by Congress to cover only cases where property is stolen while it is physically moving as part of an interstate shipment or within the custody of a carrier responsible for its transportation across state lines. The interpretation by the majority would extend federal jurisdiction over local crimes and blur boundaries between federal and state law enforcement responsibilities, which he felt was not what Congress intended when drafting this legislation. Furthermore, he expressed concern about potential misuse or abuse of power if such broad interpretations were allowed to stand without clear legislative intent supporting them.