Bryan v. United States case brief

Bryan v. United States case brief summary
524 U.S. 184 (1998)

CASE SYNOPSIS

Petitioner sought review of an order of the United States Court of Appeals for the Second Circuit that affirmed an order of the trial court convicting petitioner of willfully dealing in firearms without a federal license, a violation of 18 U.S.C.S. § 924(a)(1)(D).

CASE FACTS
Petitioner did not have a federal license to deal in firearms. Petitioner used a straw purchaser to acquire pistols he could not have purchased himself and resold the guns on street corners. Petitioner was convicted of willfully dealing in firearms without a federal license, a violation of18 U.S.C.S. § 924(a)(1)(D). As enacted, 18 U.S.C.S. § 924(a)(1)(D) contained no scienter requirement. The Firearms Owners' Protection Act added a scienter requirement to 18 U.S.C.S. § 924. The intermediate appellate court affirmed petitioner's conviction, and petitioner sought review.

DISCUSSION

• The court found that a willful act was one undertaken with a bad purpose. 
• The knowledge requisite to knowing of a violation of a statute was a factual knowledge as distinguished from knowledge of the law. 
• There was sufficient willfulness to support petitioner's conviction because he dealt in firearms and knew his conduct was unlawful. 
• The prosecutor was not required to prove petitioner knew that there was a federal law that prohibited dealing in firearms without a federal license. 
• The court affirmed because 28 U.S.C.S. § 924 did not carve out an exception to the rule that ignorance of the law was no excuse.

CONCLUSION
The order of the intermediate appellate court affirming petitioner's conviction for willfully dealing in firearms without a federal license was affirmed because the prosecutor was not required to prove petitioner knew that there was a federal law that prohibited dealing in firearms without a federal license.

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