When interpreting a statute, courts look to the plain meaning of the statute or congressional history. The notes, comments, and minutes of the drafting of the bill are all fair game to determine legislative intent. The reasoning goes that congress is deliberate in the language they choose, and the notes will tell us what they were thinking.

When looking at plain language, Often, the absence of a word or phrase gives just as legal meaning as if it were included. For example, omitting language specifying mens rea would mean that congress intends to broaden potential liability. Because they had the opportunity to make it more narrow, and they didn’t, courts infer a more broad interpretation.

From the decision: “Airplanes were well known in 1919, when this statute was passed; but it is admitted that they were not mentioned in the reports or debates in Congress. It is impossible to read words that so carefully enumerate the different kinds of motor vehicles and have no reference of any kind to aircraft...”

They also used the doctrine mentioned below to justify why airplanes weren’t included in the statute. The statute in 1919 listed off a bunch of land traveling motor vehicles, not airplanes. An omission of aircraft, and the inclusion of land vehicles specifies a class of vehicles targeted by this law. You start a pattern and you expect other items in the list to follow it. If I say I don’t want to eat food like carrots, broccoli, lettuce, cucumbers, and radishes you’d probably be safe in guessing I don’t want to eat vegetables. But it might be a stretch for you to assume I don’t like fruits.

Keep in mind that this is used to justify the overall principle, that the language of the statute should give clear warning of what the crime is. He stole an airplane and was charged with violating a statute that doesn’t clearly specify airplanes are covered. It’s not clear-by the plain meaning, legislative history, or common sense at the time-that this particular statute included airplanes. Because of that, there was no way McBoyle could have known he was violating this particular law. He might have been guilty and convicted of other crimes, but he can’t be convicted of this one.

This is why people hate law students...