Definition
"Any house" is a phrase of statutory construction appearing in criminal and regulatory codes, particularly in provisions governing burglary, arson, trespass, malicious mischief, and similar offenses that specify prohibited conduct against a "dwelling house or any other house." The operative question in legal usage is how broadly the phrase extends: which structures qualify as a "house" for purposes of a given statute, and whether modifiers like "any other house whatever" expand or limit the base category.
The phrase does not name a freestanding legal concept but functions as an interpretive unit within statutory text. Courts construing "any house" or "any other house whatever" have generally held that the phrase signals legislative intent to reach beyond residential dwellings. Under this broad reading, structures such as churches, warehouses, outbuildings, and commercial premises have been found to fall within the phrase depending on the statute's purpose and the surrounding definitional language.
Why It Matters in Research
The phrase surfaces most often in historical criminal law research — specifically in nineteenth and early twentieth century burglary and arson cases where statutes enumerated protected structures. Researchers working with those materials should understand that "any house" was not self-defining; courts routinely construed it against the backdrop of the common-law dwelling-house requirement for burglary, and the outcome depended heavily on whether the statute was read as expanding that common-law baseline or as simply cataloguing synonyms for residential structures.
The Kentucky case preserved in Bouvier (86 Ky. 12) is representative of this line: courts asked whether a church building was a "house" for statutory purposes and concluded it was, reasoning that "any other house whatever" expressed an intent to sweep broadly. Researchers encountering similar constructions in nineteenth-century statutory compilations or case reporters should treat the phrase as a signal to check the specific statute's enumeration clause — the breadth of "any house" is always relative to what the statute listed before it.
In modern research, "any house" appears less frequently as a term of art because contemporary criminal codes tend to enumerate covered structures with greater specificity (dwelling, building, structure, occupied structure, etc.) or adopt broad definitional sections. The historical phrase therefore matters primarily as a bridge concept when tracing the evolution of burglary and arson law, or when interpreting older deeds, leases, and insurance policies that use period-conventional language.
There is no significant connection between this historical criminal-law phrase and modern housing law (Fair Housing Act, landlord-tenant discrimination, inclusionary zoning). Researchers should not conflate the two domains based on the shared word "house."
Historical Dictionary Support
Bouvier's is the primary historical dictionary source for this phrase. Its entry is brief and case-specific, pointing to the Kentucky decision as authority for the proposition that "any other house whatever" reaches a church building. Bouvier does not offer a systematic definition of the phrase or trace its statutory genealogy, which is consistent with Bouvier's general approach to phrase-entries: they function as case digests more than conceptual definitions.
What Bouvier omits is the doctrinal context that makes the phrase significant. The common-law definition of burglary required breaking and entering a dwelling house in the nighttime — a residential structure actually used for habitation. As legislatures expanded burglary and arson statutes throughout the nineteenth century, the phrase "or any other house whatever" became the standard vehicle for extending protection beyond dwellings. Courts then had to decide whether "house" in that expanded clause retained any residential connotation or had become purely structural. The Kentucky holding represents the expansive view: once the legislature said "whatever," it meant it.
Other historical dictionaries (Black's, Wharton's Law Lexicon) address "dwelling house" and "burglary" in depth but do not treat "any house" as a discrete entry, leaving Bouvier's as the most direct historical dictionary source for the phrase itself.
Jurisdictional Note
Because "any house" is a phrase of statutory construction rather than a uniform legal term, its meaning has always been jurisdiction-specific and statute-specific. Nineteenth-century American jurisdictions varied considerably in how they structured their burglary and arson enumerations, and the phrase carried different weight depending on what preceded it in a given code section. Researchers should not assume that a ruling from one jurisdiction — including the Kentucky decision in Bouvier — controls interpretation in another.
Encyclopedia Cross-Reference
The encyclopedia entries linked to this term (Fair Housing Act discrimination, disparate impact doctrine, inclusionary zoning) address modern housing law and do not bear on the historical criminal-law usage of "any house." No Law Mind Encyclopedia entry directly addresses the statutory construction of this phrase. Researchers should consult entries on Burglary or Arson if available in the Criminal Law Encyclopedia for related doctrinal context.