Chatwin v. United States, 326 U.S. 455 (1946)

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Chatwin v. United States

No. 31

Argued October 10, 1945
Decided January 2, 1946 *
326 U.S. 455

CERTIORARI TO THE CIRCUIT COURT OF APPEALS

FOR THE TENTH CIRCUIT

Syllabus

1. In a prosecution for violation of the Federal Kidnapping Act, the stipulated facts as to the circumstances in which a 15-year-old girl undertook and continued a "celestial" marriage relationship with a cultist, failed to establish that she had been "held" within the meaning of the words "held for ransom or reward or otherwise" as used in the Act, and therefore convictions of the petitioners under the Act cannot be sustained.

P. 459.

(a) For aught that appears from the stipulated facts, the alleged victim was free to leave the petitioners when and if she desired; therefore, there was no proof of unlawful restraint. P. 460.

(b) There was no proof that any of the petitioners willfully intended, by force, fear, or deception, to hold the alleged victim against her will. Petitioners’ beliefs are not shown to involve unlawful restraint of celestial wives. P. 460.

(c) There was no competent or substantial proof that the girl was of such an age or mentality as necessarily precluded her from understanding the doctrine of celestial marriage and from exercising her own free will; therefore, the consent of the parents or guardian is not a factor in the case. P. 461.

(d) In the absence of evidence of the method of testing the girl’s mental age, and of proof as to the weight and significance to be attached to the particular mental age, the stipulated fact that, a year before the alleged inveiglement and detention, the girl was of the mental age of 7 cannot be said necessarily to have precluded her from judging the principles of celestial marriage and from acting in accordance with her beliefs in the matter. There must be competent proof beyond a reasonable doubt of a victim’s mental incapacity in relation to the very acts in question before the consent of the victim’s parents or guardian can become a factor. P. 462.

2. Involuntariness of the victim’s seizure and detention is of the essence of the crime of kidnapping, and if that essential element is absent, the act of participating in illicit relations or contributing to the delinquency of a minor or entering into a celestial marriage followed by interstate transportation does not violate the Federal Kidnapping Act. P. 464.

3. The purpose of the Federal Kidnapping Act was to outlaw interstate kidnappings, rather than general transgressions of morality involving the crossing of state lines, and the broad language of the Act must be interpreted and applied in the light of that purpose. P. 464.

146 F.2d 730 reversed.

Certiorari, 324 U.S. 835, to review the affirmance of convictions, 56 F.Supp. 890, of violations of the Federal Kidnapping Act.