United States v. Kirkland
United States Court of Appeals for the Eleventh Circuit
12 F.3d 199 (1994)
Michael Wayne Kirkland (defendant) was convicted of killing Donald Cook, a truck driver for a company contracted with the U.S. Postal Service to pick up and deliver mail, under 18 U.S.C. § 1114, which prohibits killing certain federal officers and employees, including "an officer or employee of the Postal Service." Cook wasn't a career postal employee: he wasn't entitled to civil-service benefits, was paid by the contractor rather than the Postal Service, and wore a badge marked "NON POSTAL SERVICE CONTRACTOR EMPLOYEE." Kirkland argued on appeal that § 1114 didn't cover Cook because the Postal Service hadn't appointed him as required by 39 U.S.C. § 1001(a).
Whether, in general, a criminal statute's description of the victim's status as an element of the crime must be limited to its unambiguous language.