In Western Laundry & Linen Co. v. United States the Ninth Circuit addressed itself to the defendant's contention that the district court had imposed double punishment by fining him and the partnership of which he was a member following criminal convictions for violations of the Sherman Act. In an opinion that seemed to leave several problems unresolved, the majority rejected the claim of double punishment.
Lee A. Chilcote,
A Criminal Antitrust Prosecution of Both Partner and Partnership--The Entity Theory and Double Jeopardy,
22 Hastings L.J. 895
Available at: https://repository.uchastings.edu/hastings_law_journal/vol22/iss4/6