McBoyle v. United States

Supreme Court of the United States · 1931 · Criminal Law

Criminal LawStatutory InterpretationNational Motor Vehicle Theft Actmotor vehicleaircraftairplanestatutory interpretationfair warning

Facts

The petitioner transported an airplane from Ottawa, Illinois, to Guymon, Oklahoma, knowing it had been stolen. He was convicted under the National Motor Vehicle Theft Act, which punishes interstate transportation of a stolen "motor vehicle." The Act defines "motor vehicle" to include an automobile, automobile truck, automobile wagon, motor cycle, or any other self-propelled vehicle not designed for running on rails. The case turned on whether an airplane falls within that statutory language.

Issue

Does the National Motor Vehicle Theft Act's definition of "motor vehicle" include an airplane, so that transporting a stolen airplane in interstate commerce is covered by the Act?

Rule

In a criminal statute, words must give fair warning in language the common world will understand. Where statutory language evokes in common understanding only vehicles moving on land, the statute should not be extended to aircraft merely because a similar policy might apply or because the legislature might have used broader words had it considered the matter.

🔒

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.

Congress makes it a felony to transport in interstate commerce a stolen "motor vehicle," defined as "an automobile, automobile truck, motor cycle, or any other self-propelled vehicle not designed for running on rails." Nolan Price knowingly flies a stolen helicopter from Tulsa, Oklahoma, to Wichita, Kansas, and is prosecuted under the statute.

Nolan's best argument for dismissal is that the statute does not cover the helicopter because:

Explanation. The majority rule is that criminal statutes must give fair warning in language the common world understands. Even though broad words like "vehicle" could be stretched etymologically, the listed examples and context indicate a land-transportation theme. A helicopter, like other aircraft, is not included where the statute evokes only vehicles moving on land.