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Brief Fact Summary. the defendant was convicted of violating the National Motor Vehicle theft Act because he intentionally conveyed a stolen airplane from Illinois to Oklahoma.
Synopsis of Rule of Law. An airplane is not defined as a ‘vehicle” within the meaning of the National Motor Vehicle Theft Act.
When a rule of conduct is laid down in words that evoke in the common mind only the picture of vehicles moving on land, the statute should not be extended to aircraft, simply because it may seem to us that a similar policy applies, or upon the speculation that, if the legislature had thought of it, very likely broader words would have been used.View Full Point of Law
Issue. Is an airplane defined as a “vehicle” within the meaning of the National Motor Vehicle Theft Act?
Held. (Holms, J.) No. an airplane is not defined as a vehicle within the meaning of the National Motor Vehicle Theft Act. There is a high probability that “a self-propelled vehicle not designed for running on rails” may be read to include any conveyance which works on road, water or air. Ordinarily, a “vehicle” implies a machine that runs on land. Looking carefully at this case, the term in the statutory definition which comes immediately before “vehicle” confirms the reading which denotes conveyances that runs only on land. Hence, McBoyle (D) was not warned by the statute that his conduct would violate the National Motor Vehicle Theft Act. Reversed.
Discussion. According to the Justice Holmes’s primer in statutory construction, before a person can be convicted of violating the law, a government must have a clear law in place. Justice Holmes also submits that the notice requirement often amounts to little more than a legal fiction, and before they violate the law, criminals often consult current statutes. Furthermore, the notice requirement promotes the salutary purpose of compelling government to govern through clear enactments that the executive branch then can enforce.