Sunday, November 17, 2013

People v. Ryan case brief

People v. Ryan case brief summary
626 N.E.2d 51 (1993)

Defendant contested the order of the Appellate Division of the Supreme Court in the Third Judicial Department (New York), affirming a judgment entered upon a verdict convicting defendant of attempted criminal possession of a controlled substance in the second degree under N.Y. Penal Law § 220.18(5). Defendant claimed that there was insufficient evidence as to the mens rea element of the crime.


  • Considering a question of statutory interpretation, the court determined that "knowingly" inN.Y. Penal Law § 220.18(5) applied to the weight of the controlled substance. 
  • The evidence at trial was insufficient to satisfy that mental culpability element. 
  • There was a mens rea element associated with the weight of the drug. 
  • There was no clear legislative intent to make the weight of a drug a strict liability element. 
  • Thus, the plain language of the statute, rules of construction, the format of the drug possession laws, and past cases all led to the conclusion that the lower court erred in holding that there was no mens rea requirement associated with the weight of a controlled substance. 
  • Thus, the court reversed defendant's conviction. 
  • The court further held that there was sufficient evidence to sustain a conviction for the lesser included offense of attempted criminal possession of a controlled substance, which did not have a weight element.

Finding a mens rea element in the charged crime which was not sufficiently proven at trial, the court reversed defendant's conviction, with leave to amend and charge to the lesser included crime.

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