In Willis v. United States (1959), the Supreme Court examined whether a defendant's constitutional rights were violated when they were not present during jury instructions in their trial. The case involved James Willis, who was convicted of bank robbery and sentenced to 25 years in prison by a federal court. He appealed his conviction on the grounds that he was absent from the courtroom when the judge gave final instructions to the jury, arguing this constituted a violation of his Fifth Amendment right to be present at all stages of his trial. The Supreme Court disagreed with Willis' argument and upheld his conviction. They ruled that while defendants have a right to be present at every stage of their trials under Rule 43 of Federal Rules for Criminal Procedure, there are exceptions where absence does not constitute an infringement upon these rights - one such exception being during jury instruction if no prejudice is shown against them due to their absence.

In the dissenting opinion for Willis v. United States, Justice Brennan disagreed with the majority's view that a defendant could be convicted of bank robbery under both Section 2113(a) and (d) of Title 18. He argued that Congress intended these sections to define separate offenses, not cumulative punishments for one act. According to him, convicting a defendant under both sections would violate the Double Jeopardy Clause of the Fifth Amendment which protects against multiple punishments for the same offense. Furthermore, he contended that if Congress had intended such cumulative punishment it would have clearly stated so in its legislation as it has done in other instances where multiple convictions were allowed from a single act or transaction.