Caminetti v. United States
Encyclopedia
Caminetti v. United States, 242 U.S. 470 (1917), was a landmark 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."
. 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 end 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.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case involving Farley Drew Caminetti
Farley Drew Caminetti
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.-Biography:...
and the Mann Act
Mann Act
The White-Slave Traffic Act, better known as the Mann Act, is a United States law, passed June 25, 1910 . It is named after Congressman James Robert Mann, and in its original form prohibited white slavery and the interstate transport of females for “immoral purposes”...
. The Court decided that the Mann Act applied not only to purposes of prostitution
Prostitution
Prostitution is the act or practice of providing sexual services to another person in return for payment. The person who receives payment for sexual services is called a prostitute and the person who receives such services is known by a multitude of terms, including a "john". Prostitution is one of...
but also to other noncommercial consensual sexual liaisons. Thus, consensual extramarital sex
Extramarital sex
Extramarital sex occurs when a married person engages in sexual activity with someone other than his or her marriage partner.Where extramarital sexual relations breach a sexual norm it may also be referred to as adultery, fornication, philandery, or infidelity...
falls within the definition of "immoral sex."
Plain Meaning Rule
The case has a historic place in American jurisprudence in that it was one of the first where the court embraced the idea of the Plain Meaning RulePlain Meaning Rule
The Plain meaning rule, also known as the literal rule, is one of three rules of statutory construction traditionally applied by English courts...
. 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 end 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.
See also
- United States v. Bitty (1911)
- List of United States Supreme Court cases, volume 242
- Athanasaw & Sampson v. United States,