McBoyle v. United States

McBoyle v. United States, 283 U.S. 25 (1931), was a United States Supreme Court case.

McBoyle v. United States
Argued February 26–27, 1931
Decided March 9, 1931
Full case nameMcBoyle v. United States
Citations283 U.S. 25 (more)
51 S. Ct. 340; 75 L. Ed. 816; 1931 U.S. LEXIS 861
Case history
PriorCertiorari to the Circuit Court of Appeals for the Tenth Circuit
Holding
The court held that since the law did not specify aircraft, it did not apply to aircraft.
Court membership
Chief Justice
Charles E. Hughes
Associate Justices
Oliver W. Holmes Jr. · Willis Van Devanter
James C. McReynolds · Louis Brandeis
George Sutherland · Pierce Butler
Harlan F. Stone · Owen Roberts
Case opinion
MajorityHolmes, joined by unanimous
Laws applied
U.S. Const.

Background

William McBoyle transported a plane that he knew to be stolen from Ottawa, Illinois to Guymon, Oklahoma.

Case

McBoyle was accused of violating the National Motor Vehicle Theft Act.[1] The petitioners claimed that since the act did not specifically mention aircraft, it did not apply to aircraft.

Decision

The court held that, since other acts – such as the Tariff Act of 1930[2] – 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

References

  1. National Motor Vehicle Theft Act, October 29, 1919, c. 89, 41 Stat 324
  2. Tariff Act, June 17, 1930, c. 997, § 401 (b)
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