McBoyle v. United States, 283 U.S. 25 (1931)
The National Motor Vehicle Theft Act cannot be interpreted to include airplanes in its definition of vehicles, since the public had no notice that Congress intended the statute to apply in this way.
Knowing at the time that it was stolen, McBoyle shipped an airplane from Illinois to Oklahoma. He was convicted of violating the National Motor Vehicle Theft Act, which covered self-propelled vehicles not designed for running on rails and prohibited them from being transported across state lines.Opinions
- Oliver Wendell Holmes, Jr. (Author)
- Charles Evans Hughes
- Willis Van Devanter
- James Clark McReynolds
- Louis Dembitz Brandeis
- George Sutherland
- Pierce Butler
- Harlan Fiske Stone
- Owen Josephus Roberts
While the prosecution's interpretation of the statute is not completely inconceivable, the word "vehicle" usually is associated with machines that run on land. The context of the statutory language surrounding this term suggests that Congress intended the more ordinary interpretation. The defendant thus had not received proper notice through the law that his conduct was illegal.Case Commentary
Even though criminals are unlikely to examine the law before deciding on a course of action, the notice requirement for a statute is important in preventing a legislature from criminalizing conduct that is overly vague and broad.
U.S. Supreme CourtMcBoyle v. United States, 283 U.S. 25 (1931)
McBoyle v. United States
Argued February 26, 27, 1931
Decided March 9, 1931
283 U.S. 25
The National Motor Vehicle Theft Act, U.S. Title 18, § 408, which punishes whoever transport, or causes to be transported, in interstate or foreign commerce a motor vehicle knowing it to have been stolen, and which defines "motor vehicle" as including "an automobile, automobile truck, automobile wagon, motor cycle, or any other self-propelled vehicle not designed for running on rails" does not apply to aircraft. P. 283 U. S. 26.
43 F.2d 273 reversed.
Certiorari, 282 U.S. 835, to review a judgment affirming a conviction under the Motor Vehicle Theft Act.