A disgruntled customer who claimed that he was sickened by food that he ate at a Pennsylvania buffet restaurant returned to the restaurant to lodge his complaints. While the customer was trying to explain his concerns, the restaurant manager interrupted the customer and then attended to other patrons. The customer became angry and walked through the restaurant, randomly discharging a handgun toward the ceiling.
The customer was charged with numerous firearms violations, including carrying a firearm without a license, discharging a firearm into a building, and recklessly endangering others. After his conviction, the customer appealed, artfully arguing that the crime of discharging a firearm into a building can be committed only by persons who shoot into a building from a location outside the building.
While his argument did little to reduce his fairly lengthy prison sentence from the other charges, the customer was successful on his appeal of discharging a firearm into a building. The Pennsylvania law that forbids discharging a firearm into a building was apparently drafted to criminalize drive by shootings, and it reads that it is a crime to discharge a firearm “into” a building “from any location.” The Pennsylvania Supreme Court found that all criminal statutes must be strictly and narrowly interpreted. In a lengthy and painstaking analysis, which included an exploration of the dictionary definition of the words “into” and “any,” the court concluded that the crime of discharging a firearm into a building only occurs when the shooter is firing into the building from some location outside the building.