The Stolen Airplane

In the late 1920s, the Defendant arranged for an airplane to be stolen from an airfield in Ottawa, Illinois, and flown across state lines to Guymon, Oklahoma, knowing the aircraft had been stolen. The federal government charged him under the National Motor Vehicle Theft Act, a law passed in 1919 to stop thieves from driving stolen cars across state lines to evade local police. The Act made it a crime to transport in interstate commerce a 'motor vehicle' known to be stolen, and defined 'motor vehicle' to include 'an automobile, automobile truck, automobile wagon, motor cycle, or any other self-propelled vehicle not designed for running on rails.' The Prosecution argued that an airplane, being self-propelled and not designed to run on rails, fit squarely within that definition. The Defense countered that when Congress wrote the statute in 1919 it was thinking of cars and trucks on the highway, not aircraft in the sky, and that no ordinary person reading the word 'vehicle' would picture an airplane. The question was whether the law reached aircraft.