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The rule of lenity ("Rule") is the canon of statutory construction that requires courts to construe ambiguous penal statutes strictly in favor of the accused.' This Comment will show that the Rule is subject to an unstated exception-an exception supported by the same quasi-constitutional norms as the Rule itself2 and reflected in both historical and contemporary practices.' The exception, which this Comment will call the "public trust exception," precludes application of the Rule when the accused holds a public trust and the crime relates to that trust. It allows a court to apply the most reasonable construction of an ambiguous criminal statute instead of the narrower one normally mandated by the Rule.4 The public trust exception imports no

A Public Trust Exception to the Rule of Lenity