United States v. Reid
206 F.Supp.2d 132, 2002 U.S. Dist. LEXIS 10564, 2002 WL 1286053 (2002)
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Rule of Law:
An airplane does not constitute a "mass transportation vehicle" under 18 U.S.C. § 1993 of the USA PATRIOT Act because, while it provides "mass transportation," the term "vehicle" as defined by the Dictionary Act (1 U.S.C. § 4) and used consistently throughout the U.S. Code refers exclusively to land-based conveyances.
Facts:
- On December 22, 2001, Richard C. Reid was a passenger on American Airlines Flight 63, an international flight from Paris to Miami.
- During the flight, a flight attendant observed Reid attempting to light the inner tongue of his sneaker, from which a wire was protruding.
- When the flight attendant intervened, Reid shoved her into a bulkhead and pushed her to the floor.
- A second flight attendant attempted to stop Reid, and he bit her on the thumb.
- Passengers came to the aid of the flight crew, subdued Reid, and injected him with sedatives for the remainder of the flight, which was diverted to Boston.
- Subsequent laboratory analysis revealed that Reid's sneakers contained functioning homemade bombs, which, if detonated, could have blown a hole in the aircraft's fuselage.
Procedural Posture:
- The United States government filed a multi-count indictment against Richard C. Reid in the U.S. District Court for the District of Massachusetts (a federal trial court).
- Count Nine of the indictment charged Reid with attempting to wreck a mass transportation vehicle, in violation of 18 U.S.C. § 1993.
- Reid filed a motion to dismiss Count Nine of the indictment, arguing that an airplane is not a "mass transportation vehicle" within the meaning of the statute.
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Issue:
Does an airplane qualify as a "mass transportation vehicle" under 18 U.S.C. § 1993, a provision of the USA PATRIOT Act?
Opinions:
Majority - Chief Judge Young
No, an airplane does not qualify as a "mass transportation vehicle" under 18 U.S.C. § 1993. The court performed a two-part statutory analysis. First, it concluded that a commercial airliner does engage in "mass transportation" as the term is defined by the statute's cross-reference, because it provides "regular and continuing general or special transportation to the public." However, the court found that an airplane is not a "vehicle." Because § 1993 does not define "vehicle," the court relied on the default definition in the Dictionary Act (1 U.S.C. § 4), which defines a "vehicle" as a contrivance used for transportation "on land." This interpretation is supported by Supreme Court precedent in McBoyle v. United States and the consistent structural distinction throughout the U.S. Code between aircraft, vessels (water), and vehicles (land). The legislative history of the USA PATRIOT Act further indicates that this section was intended to fill gaps in federal law regarding attacks on land-based systems like buses, not to create redundant protection for aircraft, which were already covered by numerous other federal criminal statutes.
Analysis:
This case is a key example of formalist statutory interpretation, demonstrating that courts will rely on established statutory definitions and the overall structure of the U.S. Code over common parlance or the perceived exigencies of a situation. The decision reinforces the principle that criminal statutes must be construed narrowly and that Congress must be precise in its legislative drafting. By refusing to expand the definition of "vehicle" to include aircraft despite the clear terrorist nature of the act, the court affirmed that pre-existing, specific statutes governing aviation crimes were the proper tools for prosecution, and that the PATRIOT Act's new provisions were meant to cover previously unprotected forms of transit.
