## Facts

- Ronnie Jones worked for Braniff International Airlines.
- Jones obtained two blank Braniff airline tickets through an acquaintance.
- Without authorization, Jones filled out and validated the tickets for use by third parties.
- The tickets were used for roundtrip travel between San Antonio, Texas and Acapulco, Mexico.
- Braniff’s business practice permitted a ticket holder to redeem a ticket for cash or another ticket of equal value if the reservation was canceled.
- Although the tickets stated they were nontransferable, Braniff ordinarily boarded the holder without checking identification.
- After a bench trial on stipulated facts, the district court convicted Jones under 18 U.S.C. § 2314 for causing forged tickets to be transported in interstate or foreign commerce.

## Issues

1. Whether the airline tickets constituted “securities” as defined by 18 U.S.C. § 2311, so that transporting forged tickets in interstate or foreign commerce could support a conviction under 18 U.S.C. § 2314.

## Decision

- The Fifth Circuit reversed the conviction.
- The court held the airline tickets were not “securities” within the meaning of 18 U.S.C. § 2311.
- Because the tickets were not “securities,” Jones’s conduct did not fall within 18 U.S.C. § 2314’s prohibition on transporting forged securities in interstate or foreign commerce.

## Legal Principles

- “Security” under 18 U.S.C. § 2311 is not read to cover every document with economic value or redeemability.
- The phrase “evidence of indebtedness” in § 2311 should not be extended to writings that, in common commercial usage, would not be treated as true debt instruments.
- An airline ticket primarily evidences a right to transportation (a contract of carriage), and a carrier’s refund or exchange practice does not convert the ticket into an “evidence of indebtedness” or other statutory “security.”
- The statutory list in § 2311 informs the scope of “security”; instruments outside the general class of listed commercial and financial paper ordinarily fall outside § 2311 and, by extension, § 2314.

## Conclusion

The Fifth Circuit vacated Jones’s § 2314 conviction, concluding that forged airline tickets—even if redeemable under an airline’s business practices—are not “securities” as defined by § 2311 and therefore cannot support liability for transporting forged securities in interstate or foreign commerce.


United States v. Jones, 450 F.2d 523 (5th Cir. 1971)