Staples v. United States case brief

 

• Staples v. US (FACTS)- ∆ was convicted b/c he hadn’t registered in the National Firearms and Registration and Transfer Record a rifle which had been modified to be capable of fully automatic fire, he claimed he didn’t know of the rifle’s automatic firing capabilities. When found guilty and sentenced to 5 yrs probation and fine, ∆ appealed, claiming that his alleged ignorance of the guns automatic capabilities should have shielded him from criminal liability. Sup Ct reversed and remanded.
  • Some indication of congressional intent, expressed or implied, is required to dispense the mens rea requirement.
  • Offenses that require no mens rea are generally disfavored.
    • Generally offenses punishable by imprisonment can’t be understood to be public welfare offenses, but must require mens rea.
    • If Congress intended to make outlaws of ignorant gun owners it would have spoken more clearly.
    • Concurrence: the issue is not whether knowledge of possession is required but what level of knowledge suffices. Conviction here requires proof that the ∆ know that he possess not only a gun but a machine gun.
    • There is no allowance made for a mistake of fact or law if an offense is strict liability in nature. Only public welfare and regulatory offenses generally impose a form of strict liability.

• Case is a question of statutory interpretation…
  • Statute has no mens rea element written into it at all.
    • Ct says that it must be construed w/ common law background w/ mens rea element
    • Freed- unregistered grenades. He didn’t know it was unregistered. No mens rea requirement b/c a grenade are dangerous in and of itself.
    • Ct distinguishes the cases by saying that numerous people innocently own guns and that is not dangerous, but having grenades is not normal and its very suspicious and dangerous so SL can hold.
  • Is it fair to categorize Freed as a regulatory crime?
    • Ct turned owning a grenade into a regulatory crime
    • Freed didn’t know grenade was unregistered while Staples didn’t know gun was unregistered (two different issues)
      • There is a distinction b/w mistake of law (ignorance isn’t an excuse) (tax code- very complicated and difficult to understand) and mistake of fact (SL) (even if you knew what the law was… you didn’t know action was unlawful- know all the facts (gun was automatic))