In Andersen v. United States, 170 U.S. 481 (1898) the Court sustained a murder conviction against the challenge that the indictment on which the verdict was returned was duplicitous in charging that death occurred through both shooting and drowning. In holding that "the Government was not required to make the charge in the alternative," id., at 504, 18 S. Ct. at 694, the Court explained that it was immaterial whether death was caused by one means or the other.