McBoyle v. United States, 283 U.S. 25 (1931), was a United States Supreme Court case regarding whether the theft of an airplane was illegal under federal law, given that the law only criminalized theft of a "vehicle."
| McBoyle v. United States | |
|---|---|
 | |
| Argued February 26–27, 1931 Decided March 9, 1931 | |
| Full case name | McBoyle v. United States |
| Citations | 283 U.S. 25 (more) 51 S. Ct. 340; 75 L. Ed. 816; 1931 U.S. LEXIS 861 |
| Case history | |
| Prior | Certiorari to the Circuit Court of Appeals for the Tenth Circuit |
| Holding | |
| The National Motor Vehicle Theft Act does not apply to aircraft. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Holmes, joined by unanimous |
| Laws applied | |
| U.S. Const. | |
Background
editWilliam McBoyle transported a plane that he knew to be stolen from Ottawa, Illinois to Guymon, Oklahoma and was arrested.
Case
editMcBoyle was accused of violating the National Motor Vehicle Theft Act on the premise that the plane was a type of "vehicle" covered by the act.[1][2] The petitioners claimed that since the act did not specifically mention aircraft, it should not apply to this case. Furthermore, Congress likely did not intend to criminalize the theft of aircraft when the law was passed, since airplanes barely existed at the time.[3]
Decision
editThe court held that, since other acts – such as the Tariff Act of 1930[4] – specifically excluded aircraft in its definition of a vehicle, the law must be interpreted narrowly. Justice Holmes stated:
Although it is not likely that a criminal will carefully consider the text of the law before he murders or steals, it is reasonable that a fair warning should be given to the world in language that the common world will understand, of what the law intends to do if a certain line is passed. To make the warning fair, so far as possible the line should be clear.
This case is a good example of the canon of ejusdem generis ("of the same kind, class, or nature").
See also
editReferences
edit- ^ National Motor Vehicle Theft Act, October 29, 1919, c. 89, 41 Stat 324
- ^ "McBoyle v. United States, 283 U.S. 25 (1931)". Justia Law. Retrieved February 4, 2024.
- ^ How Someone Stole a Plane Without Breaking Federal Law, retrieved February 4, 2024
- ^ Tariff Act, June 17, 1930, c. 997, § 401 (b)
External links
edit
Works related to McBoyle v. United States at Wikisource- Text of 283 U.S. 25 (1931) is available from: Justia Library of Congress
