Home › Case briefs › Constitutional Law

Caminetti v. United States

Supreme Court of the United States · 1917 · Constitutional Law

Constitutional LawCommerce ClauseStatutory InterpretationMann ActMann ActWhite Slave Traffic Actplain meaninginterstate commerce

Facts

Caminetti was convicted for transporting, causing transportation, and aiding transportation of a woman from California to Nevada so that she would become his mistress and concubine. Diggs was convicted on related counts involving transportation and procurement of tickets for two women, one to become his mistress and concubine and the other to become Caminetti's. Hays was convicted for persuading, inducing, enticing, and transporting an unmarried girl under eighteen from Oklahoma to Kansas with the intent that she engage in prostitution, debauchery, and other immoral practices. In none of the cases was it charged or proved that the transportation was for pecuniary gain or for prostitution for hire.

Issue

Does the White Slave Traffic Act apply only to commercialized vice or trafficking for gain, or does it also cover interstate transportation of women for noncommercial sexual immorality such as concubinage, mistress relationships, debauchery, and inducing a minor to engage in prostitution or other immoral practices? Also, may Congress constitutionally punish such transportation under its power over interstate commerce?

Rule

When a statute's words are plain and unambiguous, courts must enforce the statute according to its terms and may not narrow it by reference to titles, designating names, committee reports, or other extraneous materials. Under the Mann Act, interstate transportation of a woman or girl for prostitution, debauchery, or any other immoral purpose includes transportation to become a concubine or mistress and is not limited to cases involving commercialized vice or pecuniary gain. Congress may prohibit such use of interstate commerce under the Commerce Clause.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Ethan Rowe bought a bus ticket for Lena Ortiz to travel from Portland, Oregon, to Boise, Idaho. He intended that, once there, she would live with him in an ongoing sexual relationship outside marriage, but there was no plan to charge anyone money or operate any business.

If Ethan is prosecuted under a federal statute forbidding interstate transportation of a woman for prostitution, debauchery, or any other immoral purpose, what is the strongest argument for upholding conviction?

Explanation. The majority held that the statute's plain language is not limited to commercialized vice or pecuniary gain. "Any other immoral purpose" includes sexual immorality of the same general class as prostitution or debauchery, including transportation so a woman may become a mistress or concubine.