San Diego Law Review

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This Comment examines the judicial use of 18 U.S.C., Section 641, a penal code section designed to punish theft of money, property, and records of the United States Government, as a means to protect against the theft of employee services. The author argues that general theft statutes, such as section 641, are traditionally tied to legal concepts of property, and that the federal government possesses no property interest in the labor of its employees. The author concludes by recommending that courts strictly construe section 641 and that Congress develop a federal "theft of employee services" crime.

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