Muscarello v. United States
Citation: 524 U.S. 125 (U.S. Supreme Court, 1998)
Facts
Frank Muscarello was convicted of drug trafficking and charged under 18 U.S.C. § 924(c)(1), which imposes a mandatory five-year consecutive sentence on any person who “uses or carries a firearm” “during and in relation to” a drug trafficking crime. Muscarello had a handgun locked in his truck’s glove compartment when he completed a drug sale in a parking lot. He argued he did not “carry” the firearm in the relevant sense because it was not on his person.
Issue
Does “carries a firearm” in 18 U.S.C. § 924(c)(1) cover transporting a firearm in a vehicle (not on one’s person)?
Holding
The Court (5–4, Breyer, J.) held that “carries a firearm” includes transporting a firearm in a vehicle. The primary meaning of “carry” encompasses conveyance in a vehicle, not just on one’s person.
Rule
Courts determine plain meaning through dictionaries, ordinary usage, and literary examples. Where the plain meaning of a statutory term encompasses the defendant’s conduct, the statute applies. The rule of lenity — construing criminal statutes in favor of the defendant — applies only when there is a grievous ambiguity, not merely whenever a criminal statute’s scope is uncertain.
Significance
Muscarello is a prime vehicle for exploring dictionary use and the methodology of plain meaning analysis. Justice Breyer’s majority opinion canvasses dictionary definitions, newspaper usage, and literary examples (including the King James Bible) to establish that “carry” covers vehicle transport. Justice Ginsburg’s dissent argued that the most natural everyday meaning of “carry a firearm” is on one’s person, and that the rule of lenity should resolve any ambiguity in the defendant’s favor — illustrating that “plain meaning” is often contested.