McBoyle v. United States, 283 U.S. 25 (1931)

Case Name: McBoyle v. United States
Citation: 283 U.S. 25 (1931)

Facts: McBoyle was convicted of knowingly transporting a stolen aircraft in interstate commerce.

Issue: Whether the term “vehicle” in the NMVTA applies to aircraft.

Defendant’s argument: The definition of “vehicle” in the act specifies many land vehicles but does not mention anything about aircraft. There is nothing in the legislative history that mentioned aircraft.

State’s argument: The definition includes “any other self-propelled vehicle not designed for running on rails.” An aircraft meets this definition.

Court’s reasoning: Although a criminal is not likely to carefully consider the text of the law before committing a crime, the law should give reasonable fair warning (notice) and be written in language that the common world will understand. In everyday speech, the term “vehicle” conjures up the “picture of a thing moving on land.” Also, the definitions only list motor vehicles that move on land.

Judgment: Reversed.

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