United States v. States
United States Court of Appeals for the Eighth Circuit
488 F.2d 761 (1973)
The government (plaintiff) charged Isaac States (defendant) with mail fraud for using the postal system to defraud state election officials. The mail fraud statute originally banned any scheme to defraud, and Congress later added a second clause about schemes "for obtaining money or property." States argued the two clauses had to be read together, so that the money-or-property language limited both, meaning his indictment was defective because it didn't allege he sought money or property. The trial court refused to dismiss the indictment, States was convicted, and he appealed to the Eighth Circuit.
Whether a court may interpret an ambiguous statute by consulting the statute's text, its legislative history, and applicable precedent.