''Caminetti v. United States'', 242 U.S. 470 (1917), was a
United States Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
case involving
Farley Drew Caminetti
Farley Drew Caminetti (July 1, 1886 – December 19, 1945) 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
He was born on July 1, 1886, in Californ ...
and the
Mann Act
The White-Slave Traffic Act, also called the Mann Act, is a United States federal law, passed June 25, 1910 (ch. 395, ; ''codified as amended at'' ). It is named after Congressman James Robert Mann of Illinois.
In its original form the act mad ...
. The Court decided that the Mann Act applied not only to purposes of
prostitution
Prostitution is the business or practice of engaging in Sex work, sexual activity in exchange for payment. The definition of "sexual activity" varies, and is often defined as an activity requiring physical contact (e.g., sexual intercourse, n ...
but also to other noncommercial consensual sexual liaisons. Thus,
consensual
Consent occurs when one person voluntarily agrees to the proposal or desires of another. It is a term of common speech, with specific definitions as used in such fields as the law, medicine, research, and sexual relationships. Consent as und ...
extramarital sex
Extramarital sex occurs when a married person engages in sexual activity with someone other than their spouse.
The term may be applied to the situation of a single person having sex with a married person.
Where extramarital sexual relations do n ...
falls within the definition of "immoral sex."
Plain meaning rule
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
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".
The plain meaning rule dictates that ...
". 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.
See also
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List of United States Supreme Court cases, volume 242
This is a list of cases reported in volume 242 of ''United States Reports'', decided by the Supreme Court of the United States in 1916 and 1917.
Justices of the Supreme Court at the time of volume 242 U.S.
The Supreme Court is establis ...
*''
United States v. Bitty'' (1911)
*''
Athanasaw & Sampson v. United States'',
Notes
Further reading
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External links
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United States Supreme Court cases
United States statutory interpretation case law
1917 in United States case law
Mann Act
Sex case law
Abrogated United States Supreme Court decisions
United States Supreme Court cases of the White Court
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