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McBoyle v. United States
Citations: 283 U.S. 25; 51 S. Ct. 340; 75 L. Ed. 816; 1931 U.S. LEXIS 861Docket: 552
Court: Supreme Court of the United States; March 9, 1931; Federal Supreme Court; Federal Appellate Court
The petitioner, convicted for transporting a stolen airplane from Ottawa, Illinois, to Guymon, Oklahoma, received a three-year prison sentence and a $2,000 fine. The Circuit Court of Appeals for the Tenth Circuit affirmed this conviction. The Supreme Court granted a writ of certiorari to determine if the National Motor Vehicle Theft Act applies to aircraft. The Act defines "motor vehicle" to include various land-based self-propelled vehicles, but does not explicitly mention aircraft. The Court analyzed the definition of "vehicle," concluding that it commonly refers to land transportation. Historical legislative context, including earlier statutes and the Tariff Act of 1930, further supports the interpretation that "vehicle" excludes aircraft. The Court emphasized the need for clarity in criminal law, stating that the law should provide fair warning to individuals about what conduct is prohibited. The absence of any reference to aircraft in the statute's language indicates that Congress did not intend to include airplanes as "motor vehicles." Consequently, the judgment was reversed.