Intro to Law, pg 171-179

(Prof asked: which approach do the courts use in interpreting statutes in these cases?)

United States v. Kirby
Supreme Court of the United States, 1868.
74 U.S. (7 Wall.) 482, 19 L.Ed. 278

Facts: Sheriff arrests a mailman upon a warrant issued by a state court, which causes the mail to be late. There is a statute- the Act of Congress of March 3, 1825- which states that no one shall obstruct or delay the passage of mail or a driver carrying it.

Procedure: "The Court held that the statute had no application..."

Issue: Did the sheriff violate the statute?

Holding: No

Approach: The Golden Rule

Holy Trinity Church v. United States
Supreme Court of the United States, 1892.
143 U.S. 457, 12 S.Ct. 511, 36 L.Ed 226.

Facts: A statute existed which made it unlawful for some entity to assist the migration of an alien into the U.S. under contract to work in the U.S. The defendant was a church that had hired an Englishman to come to the U.S. to be its pastor.

Procedure: The trial court found that the church had violated the statute (by virtue of the plain language/Literal Rule approach).

Issue: Did the church violate the statute?

Holding: No

Approach: Purposive

Caminetti v. United States
Supreme Court of the United States, 1917.
242 U.S. 470, 37 S.Ct. 192, 61 L.Ed. 442.

Facts: In 1917, the Mann Act made it a crime to transport or help transport "any woman or girl for the purpose of prostitution or debauchery, or for any other immoral purpose" in interstate commerce. Caminetti transported a woman from Sacramento to Reno so that they could have an affair, which they did.

Procedure: Trial court found against defendant. He appealed, arguing the statute did not apply because he was not transporting the woman for commercial purposes.

Issue: Did he violate the statute?

Holding: Yes

Approach: Literal Rule (dissent went the opposite way by applying the Purposive Rule and invoking Holy Trinity Church)


United States v. American Trucking Ass'ns
Supreme Court of the United States, 1940.
310 U.S. 534, 60 S. Ct. 1059, 84 L.Ed. 1345.

Facts: The Motor Carrier Act of 1935 gave the Interstate Commerce Commission the duty to regulate the qualifications and maximum hours of service of employees and safety of operation and equipment involved in "common carriers" (i.e. trucking). The commission regulated the the hours of the drivers, and then congress passed another statute regulating the hours of all workers except those covered by the Interstate Commerce Commission- by way of which the Commission concluded that it only had jurisdiction over drivers. Plaintiffs, a carrier company, wish to force the Commission to exercise its supposed jurisdiction over all its other employees.

Procedure: Plaintiffs filed a petition with the Commission to that effect, which it denied. The plaintiffs then went to a district court, whom decided for the plaintiff (based on Literal Rule).

Issue: Should the Commission expand the practice of its jurisdiction?

Holding: No.

Approach: Dissenters agreed with the Literal rule; majority argued Purposive.