In Holloway v. United States, the United States Supreme Court considered whether the scienter requirement of the Federal carjacking statute was satisfied where the assailant's intent to cause death or serious bodily harm was conditioned upon the victim's refusal to give up the vehicle. The Court found that, as neither conditional nor unconditional content is mentioned in the statute, a reasonable reading of the statute encompasses both species of intent. Further, because Congress's intent in enacting the statute was clear, the Court stated that the rule of lenity was not applicable. The note argues that the majority in Holloway erred in holding that proof of conditional intent to kill satisfies the scienter requirement of the hijacking statute. Contrary to the Court's conclusion, the most reasonable interpretation of the statute does not cover conditional intent. Moreover, the legislative history is unclear, and it is entirely plausible that Congress intended this statute to cover only a specific type of carjacking. The note claims that, at the very least, the statute is ambiguous and therefore the rule of lenity should apply. Notes