Opinion · Supreme Court of the United States

McBoyle v. United States

283 U.S. 25

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
1931-03-09
Topic
general

How later courts describe this case

  • holding that “any other self-propelled vehicle,” when preceded by “automobile, automobile truck, automobile wagon, and motorcycle” did not include aircraft
  • observing that judicial statutory construction cannot proceed "upon the speculation that, if the legislature had thought of it, very likely broader words would have been used"
  • applying rule of lenity to civil forfeiture provisions that are punitive and quasi-criminal in nature
  • exploring problems facing courts when asked to apply statutes to disputes the nuances of which were not contemplated by the enacting legislators
  • refusing to expand a criminal statute's reach without "a fair warning ... given to the world in language the common world will understand"
  • utilizing the ejusdem generis principle in determining that “automobile, automobile truck, automobile wagon, motor cycle, or any other self-propelled vehicle not designed for running on rails” did not apply to an airplane
  • adopting 13 See 1989 OED, available at https://oed.com/oed2/00164865 (same). the meaning assigned to a word “in everyday speech,” even though “[n]o doubt etymologically it is possible to use the word to signify” something else
  • declining “to read words that so carefully enumerate the different forms of motor vehicles” that are subject to the National Motor Vehicle Theft Act as including airplanes where the statute contains “no reference of any kind to aircraft”

Citator

UpLaw has not yet analyzed McBoyle v. United States. The absence of a flag is not a finding that it is good law.

Cited by
513 opinions

Headnotes

  1. Criminal Law & Procedure — Statutory Interpretation The National Motor Vehicle Theft Act, which defines "motor vehicle" to include "any other self-propelled vehicle not designed for running on rails," does not apply to aircraft, because the word "vehicle" in everyday speech connotes a thing moving on land, and the statutory enumeration of motor vehicles contains no reference to aircraft. 283 U.S. at 26
  2. Criminal Law & Procedure — Rule of Lenity and Fair Warning A criminal statute should not be extended beyond the meaning its words convey to the common understanding merely because a similar policy might seem to apply or because broader words might have been used had the legislature thought of the situation; fair warning requires that the line of prohibited conduct be clear in language the common world will understand. 283 U.S. at 26