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Legislation and Regulation Keyed to Manning, 5th Ed.
Moskal v. United States
Citation:
498 U.S. 103 (1990)Facts
Raymond Moskal participated in an interstate “title-washing” scheme that operated between Pennsylvania and Virginia. Confederates purchased used cars in Pennsylvania, rolled back their odometers, and altered the titles to reflect the lower mileage figures. These altered titles were then sent to an accomplice in Virginia, who submitted them to Virginia authorities. The Virginia officials, unaware of the alterations, issued new Virginia titles that incorporated the false mileage figures. These “washed” titles were then sent back to Pennsylvania and used to sell cars to unsuspecting buyers. Moskal played two roles in this scheme: he sent altered titles from Pennsylvania to Virginia and received the “washed” titles when they were returned. The government indicted and convicted Moskal under 18 U.S.C. §2314 for receiving two washed titles, each recording a mileage figure that was 30,000 miles lower than the actual mileage.
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