McBoyle v. United States
283 U.S. 25 (1931)
Rule of Law:
Criminal statutes must be interpreted based on the common, ordinary meaning of their terms to provide fair warning to the public, and any ambiguity should be resolved in favor of the defendant.
Facts:
- In 1919, Congress passed the National Motor Vehicle Theft Act.
- The Act defined a 'motor vehicle' as an 'automobile, automobile truck, automobile wagon, motor cycle, or any other self-propelled vehicle not designed for running on rails.'
- William McBoyle transported an airplane from Ottawa, Illinois, to Guymon, Oklahoma.
- McBoyle knew the airplane he was transporting had been stolen.
Procedural Posture:
- William McBoyle was charged and convicted in a federal trial court for violating the National Motor Vehicle Theft Act.
- McBoyle, as appellant, appealed his conviction to the U.S. Circuit Court of Appeals for the Tenth Circuit.
- The Circuit Court of Appeals affirmed the trial court's judgment.
- McBoyle, as petitioner, was granted a writ of certiorari by the Supreme Court of the United States to review the lower court's decision.
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Issue:
Does the term 'motor vehicle' in the National Motor Vehicle Theft Act, which is defined to include 'any other self-propelled vehicle not designed for running on rails,' encompass an airplane?
Opinions:
Majority - Mr. Justice Holmes
No. The term 'motor vehicle' in the National Motor Vehicle Theft Act does not encompass an airplane because the statute's language and context refer to vehicles that operate on land. The court reasoned that in everyday language, the word 'vehicle' evokes the image of a device for land transportation. The statute's specific enumeration of automobiles, trucks, and motorcycles reinforces this interpretation, suggesting that the general phrase 'any other self-propelled vehicle' is limited to the same class of land-based conveyances. Although airplanes were well-known when the Act was passed in 1919, they were not mentioned in the legislative debates or reports. Crucially, criminal laws must provide 'fair warning' in language that the public can commonly understand, and a court should not extend a statute's reach to include unenumerated items, even if a similar policy might apply.
Analysis:
This case is a landmark example of the 'rule of lenity' in statutory interpretation, which dictates that ambiguous criminal statutes should be construed narrowly and in favor of the accused. The decision solidifies the due process principle that individuals must have fair warning of what conduct is criminal. It instructs courts to resist expanding the scope of criminal laws based on perceived legislative intent or policy goals, instead prioritizing the plain, ordinary meaning of the text. This precedent compels legislatures to be specific and clear when defining criminal offenses, especially those involving new technologies.
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