McElroy v. United States

Background

Charles McElroy, a man from Ohio, was charged after stolen union checks were used to buy a car and a boat in Pennsylvania. The checks bore forged signatures. He was convicted under a federal law that bans transporting forged securities in interstate commerce. McElroy argued the law required proof that the forgery occurred before the checks crossed the state line into Pennsylvania.

Reasoning

The Court focused on whether “interstate commerce” covers movement that continues inside the destination State. It examined the statute’s origins and earlier decisions and concluded Congress intended the phrase to cover the whole stream of interstate movement, not only the moment an item crosses a border. The Court rejected the argument for reading the statute narrowly under the rule of lenity and held the jury could be instructed that continued in-state movement counts if it is a continuation of an interstate trip. The Court therefore affirmed the convictions on the forged-check counts.

Real world impact

The ruling allows federal prosecutors to charge people who use forged checks during trips that began in another State, even if the forgery occurred after crossing the border. It clarifies that similar federal stolen-property statutes reach items still moving as part of an interstate journey. The holding is limited: if the entire obtaining, forging, and passing of the checks occurred solely within one State, federal law would not apply.

Dissents or concurrances

Justice Stevens dissented, arguing the statute and its legislative history show Congress meant to reach only items actually transported across state lines and warning against expanding federal criminal reach.