Moskal v. United States
United States Supreme Court
498 U.S. 103 (1990)
Raymond Moskal (defendant) participated in a car-title-washing scheme, buying used cars in Pennsylvania, rolling back their odometers, and altering their titles to reflect false mileage before an accomplice took the altered titles to Virginia, where unwitting officials issued new titles reflecting the false readings, which were then brought back to Pennsylvania to help sell the tampered cars. Moskal was convicted under the National Stolen Property Act, which prohibits interstate commerce in falsely made securities, and he appealed, arguing the washed titles -- though containing false information -- were genuine documents issued by real government officials and thus not 'falsely made'; the court of appeals upheld the conviction, and the Supreme Court granted certiorari.
Whether, if a statute uses words that have both ordinary and legal meanings, a court should look to the words' ordinary meanings if doing so better gives effect to the legislature's purpose.