Moskal v. United States

Background

A man who took part in a “title‑washing” scheme was convicted after his confederates bought used cars in Pennsylvania, rolled back the odometers, and altered the titles. Those altered Pennsylvania titles were sent to an accomplice in Virginia. Virginia officials, unaware of the fraud, issued new state titles reflecting the false mileage. The washed titles were returned to Pennsylvania and used in sales. The defendant sent altered titles and later received the washed titles; he was charged for receiving two titles each showing 30,000 miles less than true.

Reasoning

The central question was whether a state‑issued title that is genuine in form but contains false mileage can be “falsely made” under 18 U.S.C. §2314. The Court rejected a narrow reading and the defendant’s plea for lenity. It held that “falsely made” describes the character of the document and can include genuine state titles that contain materially false information when transported with unlawful or fraudulent intent. The Court relied on the statute’s plain language and Congress’ purpose to combat interstate fraud and affirmed the conviction.

Real world impact

The decision makes clear that people who traffic in washed vehicle titles can face federal charges when they knowingly move or receive those titles across state lines with fraudulent intent. That empowers federal prosecutors to pursue multi‑state title and odometer schemes and may lead to closer mileage and title checks in used‑car sales.

Dissents or concurrances

A dissent argued the phrase “falsely made” traditionally meant falsity in execution, not falsity of content, and warned against expanding a criminal statute beyond its common‑law meaning; three Justices joined that view.