Caminetti v. United States | |
---|---|
Argued November 13–14, 1916 Decided January 15, 1917 | |
Full case name | F. Drew Caminetti v. United States; Maury I. Diggs v. United States; L.T. Hays v. United States |
Citations | 242 U.S. 470 ( more ) 37 S. Ct. 192; 61 L. Ed. 442 |
Case history | |
Prior | Diggs v. United States, 220 F. 545 (9th Cir.), cert. granted, 238 U.S. 637(1915). Hays v. United States, 231 F. 106 (8th Cir.), cert. granted, 241 U.S. 674(1916). |
Holding | |
The Mann Act applied not only to purposes of prostitution but also to other noncommercial consensual sexual liaisons. Thus, consensual extramarital sex falls within the genre of "immoral practice." | |
Court membership | |
| |
Case opinions | |
Majority | Day, joined by Holmes, Van Devanter, Pitney, Brandeis |
Dissent | McKenna, joined by White, Clarke |
McReynolds took no part in the consideration or decision of the case. | |
Laws applied | |
White-Slave Traffic (Mann) Act, ch. 395, 36 Stat. 825 (1910) (codified as amended at 18 U.S.C. §§ 2421-2424). | |
Overruled by | |
Lawrence v. Texas , 539 U.S. 558 (2003) (non commercial consensual private sex acts of adults) | |
Abrogated by | |
Child Sexual Abuse & Pornography Act of 1986, Pub. L. No. 99-628, § 5(b)(1), 100 Stat. 3510–11 (in part) |
Caminetti v. United States, 242 U.S. 470 (1917), was a United States Supreme Court case involving Farley Drew Caminetti and the Mann Act. The Court decided that the Mann Act applied not only to purposes of prostitution but also to other noncommercial consensual sexual liaisons. Thus, consensual extramarital sex falls within the definition of "immoral sex."
The case has an historic place in American jurisprudence in that it was one of the first where the court embraced the idea of the "plain meaning rule". This is a form of legislative interpretation that focuses strongly on the literal text of a statute. In its most extreme form the plain meaning rule does not look outside of the statutory text at any additional sources to find the legislative intent if the rule is "plain" from the text. Critics of using the plain meaning rule argue that a court may find or not find an ambiguity in a statute depending on the result that a court sees fit.
The issue in the case that caused the Court to interpret using the plain meaning rule was whether the Mann Act's inclusion of the phrase "...or for any other immoral purpose..." included Caminetti's actions. The Court found that Caminetti had been convicted of transporting a woman across state lines for an immoral purpose which, according to the majority opinion, was well within the plain meaning of the statute.
The White-Slave Traffic Act, also called the Mann Act, is a United States federal law, passed June 25, 1910. It is named after Congressman James Robert Mann of Illinois.
Bauer & Cie. v. O'Donnell, 229 U.S. 1 (1913), was a 1913 United States Supreme Court decision involving whether a purchaser of a patented product bearing a price-fixing notice incurs guilt of patent infringement by reselling the product at a price lower than that which the notice commands. A divided Court (5–4) held that it was not.
Sodomy laws in the United States, which outlawed a variety of sexual acts, were inherited from colonial laws in the 17th century. While they often targeted sexual acts between persons of the same sex, many statutes employed definitions broad enough to outlaw certain sexual acts between persons of different sexes, in some cases even including acts between married persons.
Proposition 22 was a law enacted by California voters in March 2000 stating that marriage was between one man and one woman. In November 2008, Proposition 8 was also passed by voters, again only allowing marriage between one man and one woman.
Statutory interpretation is the process by which courts interpret and apply legislation. Some amount of interpretation is often necessary when a case involves a statute. Sometimes the words of a statute have a plain and a straightforward meaning. But in many cases, there is some ambiguity in the words of the statute that must be resolved by the judge. To find the meanings of statutes, judges use various tools and methods of statutory interpretation, including traditional canons of statutory interpretation, legislative history, and purpose. In common law jurisdictions, the judiciary may apply rules of statutory interpretation both to legislation enacted by the legislature and to delegated legislation such as administrative agency regulations.
The plain meaning rule, also known as the literal rule, is one of three rules of statutory construction traditionally applied by English courts. The other two are the "mischief rule" and the "golden rule".
Textualism is a formalist theory in which the interpretation of the law is primarily based on the ordinary meaning of the legal text, where no consideration is given to non-textual sources, such as intention of the law when passed, the problem it was intended to remedy, or significant questions regarding the justice or rectitude of the law.
Gregory v. Helvering, 293 U.S. 465 (1935), was a landmark decision by the United States Supreme Court concerned with U.S. income tax law. The case is cited as part of the basis for two legal doctrines: the business purpose doctrine and the doctrine of substance over form. The business purpose doctrine is essentially that if a transaction has no substantial business purpose other than the avoidance or reduction of Federal tax, the tax law will not regard the transaction. The doctrine of substance over form is essentially that for Federal tax purposes, a taxpayer is bound by the economic substance of a transaction if the economic substance varies from its legal form.
Dolan v. United States Postal Service, 546 U.S. 481 (2006), was a case decided by the Supreme Court of the United States, involving the extent to which the United States Postal Service has sovereign immunity from lawsuits brought by private individuals under the Federal Tort Claims Act. The Court ruled that an exception to the FTCA that barred liability for the "negligent transmission of mail" did not apply to a claim for injuries caused when someone tripped over mail left by a USPS employee. Instead, the exception only applied to damage caused to the mail itself or that resulted from its loss or delay.
Pepper v Hart [1992] UKHL 3, is a landmark decision of the House of Lords on the use of legislative history in statutory interpretation. The court established the principle that when primary legislation is ambiguous then, in certain circumstances, the court may refer to statements made in the House of Commons or House of Lords in an attempt to interpret the meaning of the legislation. Before this ruling, such an action would have been seen as a breach of parliamentary privilege.
Hoke v. United States, 227 U.S. 308 (1913), was a decision by the United States Supreme Court that held that the United States Congress could not regulate prostitution per se, which was strictly the province of the states. Congress could, however, regulate interstate travel for purposes of prostitution or other "immoral purposes."
The Anti-Obscenity Enforcement Act of 1998 is an Alabama statute that criminalizes the sale of sex toys. The law has been the subject of extensive litigation and has generated considerable national controversy.
The purposive approach is an approach to statutory and constitutional interpretation under which common law courts interpret an enactment within the context of the law's purpose.
Cleveland v. United States, 329 U.S. 14 (1946), was a case in which the Supreme Court of the United States held that notwithstanding the fact that polygamy is a person's religious belief, the Mann Act prohibits the transportation of women across state lines to participate in polygamy.
Farley Drew Caminetti was charged with violation of the Mann Act and his case was settled by the United States Supreme Court as Caminetti v. United States.
Church of the Holy Trinity v. United States, 143 U.S. 457 (1892), was a decision of the Supreme Court of the United States regarding an employment contract between The Church of the Holy Trinity, New York and an English (Anglican) priest.
Lesbian, gay, bisexual, and transgender (LGBT) persons in the U.S. commonwealth of Kentucky still face some legal challenges not experienced by other people. Same-sex sexual activity is legal in Kentucky. Same-sex couples and families headed by same-sex couples are not eligible for all of the protections available to opposite-sex married couples. On February 12, 2014, a federal judge ruled that the state must recognize same-sex marriages from other jurisdictions, but the ruling was put on hold pending review by the Sixth Circuit. Same sex-marriage is now legal in the state under the U.S. Supreme Court ruling in Obergefell v. Hodges. The decision, which struck down Kentucky's statutory and constitutional bans on same-sex marriages, and all other same sex marriage bans elsewhere in the country, was handed down on June 26, 2015.
Franklin v. State, 257 So. 2d 21, was a case in which the Florida Supreme Court struck down Florida's sodomy law as being "unconstitutional for vagueness and uncertainty in its language, violating constitutional due process to the defendants." The court retained the state's prohibition on sodomy by ruling that anal and oral sex could still be prosecuted under the lesser charge of "unnatural and lascivious" conduct, thus reducing the crime from a felony to a misdemeanor.