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Manslaughter is not punishable in the courts of the United States unless it is committed on the high seas. Though penal laws are to be construed strictly, they are not to be construed so strictly as to defeat the obvious intention of the legislature. Thus, the intention of the legislature is to be collected from the words they employ. Where there is no ambiguity in the words, there is no room for construction.
Defendant Wiltberger was prosecuted in a federal court for manslaughter for the crime he committed while aboard a ship in a river basin. The indictment was founded under the Act of April 30, 1790, § 12 entitled, "An Act for the Punishment of Certain Crimes Against the United States. A certification was granted to review a judgment from the circuit court of Pennsylvania to review whether defendant was properly prosecuted.
Was the defendant properly prosecuted for manslaughter?
The court ruled that defendant was not properly prosecuted in a federal court for manslaughter under the subject statute because it was clear that the legislature intended for federal jurisdiction to exist over manslaughter cases committed while aboard a ship on the high seas, and defendant's crime was committed while aboard a ship in a river basin. The court held that although the crime of manslaughter was traditionally connected to the crime of murder and the provision of the statute relating to murder enumerated several places in which federal jurisdiction was invoked, nothing in the language of the provision relating to manslaughter authorized the court to employ principles of judicial construction to apply the enumeration of places to defendant's crime.