United States v. Kirby (1868) – Case Brief Summary (U.S. Supreme Court)

In United States v. Kirby (1868) 74 U.S. 482, the Supreme Court held that a defendant was not guilty of obstructing the passage of the mails by arresting a mail carrier upon a valid warrant arising out of a murder indictment.

The principle that statutory language should not be construed to produce an absurd result is a deeply rooted one. Over 130 years ago, the United States Supreme Court interpreted a statute which, under its plain terms, made it illegal in all instances to obstruct the passage of mail or a mail carrier.

The Court held that the statute did not apply to a sheriff who executed an arrest warrant against a mail carrier while he was delivering mail.

In so holding, the Court cited two instances, both centuries old, where the plain language of a law was not followed because doing so produced an absurd result:

"The common sense of man approves the judgment mentioned by Puffendorf, that the Bolognian law which enacted, `that whoever drew blood in the streets should be punished with the utmost severity,' did not extend to the surgeon who opened the vein of a person that fell down in the street in a fit. The same common sense accepts the ruling, cited by Plowden, that the statute of 1st Edward II, which enacts that a prisoner who breaks prison shall be guilty of felony, does not extend to a prisoner who breaks out when the prison is on fire - `for he is not to be hanged because he would not stay to be burnt.'"

The Supreme Court said:

"All laws should receive a sensible construction. General terms should be so limited in their application as not to lead to injustice, oppression, or an absurd consequence. The reason of the law, in such cases, should prevail over its letter."