to the legislative history for guidance.” Holland, 181 F.3d at 603 (internal quotation marks omitted). And, then, “[i]f congressional intent is not apparent from an examination of the legislative history, we apply the traditional tools of statutory construction.” Id. (internal quotation marks omitted). Prior to 1994, the mail fraud statute criminalized the use of the United States Postal Service to execute a fraudulent scheme, but had no application to private or commercial interstate carriers. See United States v. Lefkowitz, 125 F.3d 608, 617 (8th Cir.1997). Then, as now, the statute made no distinction between intrastate and interstate mailings, and it had been extended to both as a proper exercise of the Postal Power. See United States v. Elliott, 89 F.3d 1360, 1364 (8th Cir.1996) (<HOLDING>). In 1994, however, Congress broadened the
holding that the aedpa statute of limitations is not jurisdictional holding that whenever a person uses the united states post office to deposit to transport and to deliver parcels money or other material by means of the mail that person clearly and unmistakably has used a facility in interstate commerce irrespective of the intrastate destination of the item mailed and that such intrastate use satisfies the jurisdictional requirement of the travel act recognizing that congress had the power to regulate boxcars that traveled exclusively intrastate because of their inherent mobility and connection to interstate commerce it is no objection to such an exertion of commerce clause power that the dangers intended to be avoided arise in whole or in part out of matters connected with intrastate commerce holding that the jurisdictional basis of the mail fraud statute is grounded in the postal power and therefore necessarily encompasses all items passing through the united states mails even if their passage is purely intrastate recognizing the existence of purely jurisdictional elements