McBoyle v. United States

McBoyle v. United States, 283 U.S. 25 (1931), was a United States Supreme Court case regarding whether the theft of an airplane was illegal under federal law, given that the law only criminalized theft of a "vehicle."

Background
William McBoyle transported a plane that he knew to be stolen from Ottawa, Illinois to Guymon, Oklahoma and was arrested.

Case
McBoyle was accused of violating the National Motor Vehicle Theft Act on the premise that the plane was a type of "vehicle" covered by the act. The petitioners claimed that since the act did not specifically mention aircraft, it should not apply to this case. Furthermore, Congress likely did not intend to criminalize the theft of aircraft when the law was passed, since airplanes barely existed at the time.

Decision
The court held that, since other acts – such as the Tariff Act of 1930 – specifically excluded aircraft in its definition of a vehicle, the law must be interpreted narrowly. Justice Holmes stated:

"Although it is not likely that a criminal will carefully consider the text of the law before he murders or steals, it is reasonable that a fair warning should be given to the world in language that the common world will understand, of what the law intends to do if a certain line is passed. To make the warning fair, so far as possible the line should be clear."

This case is a good example of the canon of ejusdem generis ("of the same kind, class, or nature").