Dobyns v. United States
30 A.3d 155
| D.C. | 2011Background
- Dobyns convicted in the DC Superior Court of second-degree theft under DC Code § 22-3211. The theft allegedly involved taking Harris's car in Maryland but Dobyns was arrested in DC and alleged the offense occurred outside DC.
- Harris lent the car in Forestville, MD; after two requests for return, Dobyns delivered a different car and failed to return hers; Harris filed a Maryland police report alleging theft.
- After the Maryland report, MPD stopped Dobyns in DC driving Harris's car and arrested him for an unrelated offense.
- At trial, no jurisdiction challenge was raised; on appeal, Dobyns argues the theft occurred solely in Maryland, so DC court lacked subject-matter jurisdiction.
- DC Superior Court had subject-matter jurisdiction because all elements of theft occurred in DC, including unauthorized use of the vehicle within DC.
- The court considers whether the plain meaning of the theft statute § 22-3211 encompasses Dobyns’s conduct, and whether legislative history overrides that meaning; it does not.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Superior Court had subject-matter jurisdiction over the theft | Dobyns argues theft occurred in Maryland, outside DC | State argues elements occurred in DC; jurisdiction lies where unauthorized use happened | Yes; DC court had jurisdiction; unauthorized use occurred in DC and law applies |
Key Cases Cited
- People's Drug Stores, Inc. v. District of Columbia, 470 A.2d 751 (D.C.1983) (plain meaning governs statutory interpretation in DC code)
- Byrd v. United States, 598 A.2d 386 (D.C.1991) (legislative history may inform interpretation)
- Morrison v. United States, 547 A.2d 996 (D.C.1988) (precedent regarding pre-1982 theft distinctions)
- In re R.K.S., 905 A.2d 201 (D.C.2006) (UUV framework showing use within DC suffices for jurisdiction)
- 1618 Twenty-First Street Tenants' Ass'n, v. The Phillips Collection, 829 A.2d 201 (D.C.2003) (borrows of terms-of-art and context in statutory construction)
- Dyson v. United States, 848 A.2d 603 (D.C.2004) (jurisdiction reviewed de novo; law applied without waiver)
- Long v. United States, 940 A.2d 87 (D.C.2007) (burden-shifting in jurisdictional proof)
- Brown v. United States, 35 App.D.C. 548 (1910) (predecessor larceny/ theft distinctions referenced)
- United States v. Cotton, 535 U.S. 625 (2002) (subject-matter jurisdiction cannot be forfeited)