In the 1930 case McBoyle v. United States, the U.S Supreme Court ruled that an airplane did not qualify as a vehicle under the National Motor Vehicle Theft Act of 1919. The defendant, William McBoyle, had been convicted for transporting a stolen aircraft across state lines. However, he appealed his conviction on grounds that an airplane was not considered a "motor vehicle" according to federal law at that time. The court agreed with him and overturned his conviction in a unanimous decision written by Justice Oliver Wendell Holmes Jr., who noted that while it might seem logical to include airplanes within the definition of vehicles due to their mode of transportation being similar to cars or motorbikes; however, because they were not specifically mentioned in legislation when it was drafted (as air travel was still relatively new), they could not be included within its scope without explicit amendment from Congress.

In the MCBOYLE v. UNITED STATES case, there was no dissenting opinion recorded. The unanimous decision of the court was delivered by Justice Oliver Wendell Holmes Jr., who ruled that an airplane did not fall under the definition of a vehicle in terms of interstate transportation laws at that time and therefore, McBoyle could not be charged with theft under those specific regulations.