Tinder v. United States

Background

A man pleaded guilty to six counts for taking six separate letters from mailboxes and was sentenced to three years on each count to run at the same time. After about a year he filed a federal motion to correct his sentence, arguing the indictment did not say any letter was worth more than $100 and so the charges should have been misdemeanors with a one-year maximum instead of felonies with a five-year maximum. Lower courts rejected him and one appeals court’s view conflicted with another circuit.

Reasoning

The core question was whether the smaller penalty applied when intact letters were stolen without alleging value. The Court looked to the statute’s words, the law’s history, and the Reviser's Note added in 1948 stating a smaller penalty was meant for items of $100 or less. The Justices agreed the phrase “any such article or thing” should include letters themselves, so the man had been improperly treated as a felon. Because Congress later amended the law, that change could not undo relief for earlier convictions.

Real world impact

The ruling sends the case back so the lower court can correct the man’s sentence under the law as it stood when he was convicted. It clarifies that under the old wording intact letters could fall within the smaller penalty when value was not alleged. Congress later removed the misdemeanor provision for future cases, but that change does not prevent correction of past sentences.

Dissents or concurrances

Three Justices dissented and would have left the appellate court’s decision in place for the reasons stated in the Fourth Circuit opinion.