Since 1930 the law has made it an offense to take and drive away a motor vehicle without the consent of the owner. Subsequent amendments and new laws have clarified the offense and the penalties and have eliminated the requirement that the car be driven away. Issues clarified in judicial decisions have been the nature of an attempt, intent, whether the vehicle must be used as a conveyance, whether a voluntary action is necessary for taking, jokes, and the definition of a conveyance. Additional issues have included the nature of the journey involved and whether consent to use a vehicle was obtained by fraudulent misrepresentations. A recent survey revealing that one person in three leaves a vehicle unlocked at some time and that only 15 percent of vehicles are equipped with engine cut-out devices suggests the need for more effective theft prevention measures and vehicle security.