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Moskal v. United States

United States Supreme Court
498 U.S. 103 (1990)


Facts

Raymond Moskal (defendant) was involved in a fraudulent scheme to sell used cars with tampered odometers through a process called title washing. Moskal, together with other participants in the scheme, bought used cars in Pennsylvania and set back the cars’ odometers. Moskal then changed the mileage recorded on the cars’ titles. An accomplice took the altered titles to Virginia, where unwitting state officials issued new titles that reflected the false odometer readings. The new, or washed, titles were returned to Pennsylvania and used to better market the tampered vehicles. Moskal was convicted for violating the National Stolen Property Act (Act), which prohibited interstate commerce involving falsely made securities. Moskal appealed his conviction, claiming that the washed titles were not falsely made. Although the titles contained false information, the titles were nonetheless genuine documents issued by government officials in Virginia. The court of appeals upheld Moskal’s conviction, and the United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Marshall, J.)

Dissent (Scalia, J.)

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