Caminetti v. United States

Caminetti v. United States, 242 U.S. 470 (1917), was a United States Supreme Court case involving Farley Drew Caminetti and the Mann Act. The Court decided that the Mann Act applied not only to purposes of prostitution but also to other noncommercial consensual sexual liaisons. Thus, consensual extramarital sex falls within the definition of "immoral sex."

Caminetti v. United States
Argued November 13–14, 1916
Decided January 15, 1917
Full case nameF. Drew Caminetti v. United States; Maury I. Diggs v. United States; L.T. Hays v. United States
Citations242 U.S. 470 (more)
37 S. Ct. 192; 61 L. Ed. 442
Case history
PriorDiggs v. United States, 220 F. 545 (9th Cir.), cert. granted, 238 U.S. 637 (1915). Hays v. United States, 231 F. 106 (8th Cir.), cert. granted, 241 U.S. 674 (1916).
Holding
The Mann Act applied not only to purposes of prostitution but also to other noncommercial consensual sexual liaisons. Thus, consensual extramarital sex falls within the genre of “immoral practice.”
Court membership
Chief Justice
Edward D. White
Associate Justices
Joseph McKenna · Oliver W. Holmes Jr.
William R. Day · Willis Van Devanter
Mahlon Pitney · James C. McReynolds
Louis Brandeis · John H. Clarke
Case opinions
MajorityDay, joined by Holmes, Van Devanter, Pitney, Brandeis
DissentMcKenna, joined by White, Clarke
McReynolds took no part in the consideration or decision of the case.
Laws applied
White-Slave Traffic (Mann) Act, ch. 395, 36 Stat. 825 (1910) (codified as amended at 18 U.S.C. §§ 2421-2424).
Overruled by
Lawrence v. Texas, 539 U.S. 558 (2003)
(non commercial consensual private sex acts of adults)
Abrogated by
Child Sexual Abuse & Pornography Act of 1986, Pub. L. No. 99-628, § 5(b)(1), 100 Stat. 3510–11 (in part)

Plain meaning rule

The case has a historic place in American jurisprudence in that it was one of the first where the court embraced the idea of the “plain meaning rule”. This is a form of legislative interpretation that focuses strongly on the literal text of a statute. In its most extreme form the plain meaning rule does not look outside of the statutory text at any additional sources to find the legislative intent if the rule is "plain" from the text. Critics of using the plain meaning rule argue that a court may find or not find an ambiguity in a statute depending on the end result that a court sees fit.

The issue in the case that caused the Court to interpret using the plain meaning rule was whether the Mann Act's inclusion of the phrase “...or for any other immoral purpose...” included Caminetti's actions. The Court found that Caminetti had been convicted of transporting a woman across state lines for an immoral purpose which, according to the majority opinion, was well within the plain meaning of the statute.

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See also

Notes

    Further reading
    • Anderson, Robert L. (1990). The Diggs–Caminetti case, 1913–1917: For Any Other Immoral Purpose. Studies in Twentieth Century American History. 1. Lewiston, NY: E. Mellen Press. ISBN 0-88946-320-4.
    • Huston, John A. (1947). "Prosecution of Mormon "Fundamentalists" under the Mann Act—Doctrine of Caminetti v. United States". Michigan Law Review. The Michigan Law Review Association. 45 (6): 785–787. doi:10.2307/1283936. JSTOR 1283936.


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