The opinions of the court in Nofziger are symbolic of the fundamental problems involved in interpreting the Federal criminal code. The revisions of subsection 207(c) are symbolic of the fundamental problems involved in drafting the Federal criminal code. Neither statutes nor case law provide a useful principle to guide courts when they interpret the thousands of disparate provisions contained in Title 18. Over 10 years ago, in United States v. Bailey, 444 U.S. 400 (1980), the Supreme Court took the first tentative steps toward filling the void. The States are leaders in this area, with a majority of States modernizing their criminal codes and regularizing their methods of statutory interpretation over the last 30 years. A similar development has not occurred with the Federal criminal code, in spite of the fact that the Federal criminal justice system possesses the capacity for reform. 232 notes