Sunday, November 17, 2013

Stepniewski v. Gagnon case brief

Stepniewski v. Gagnon case brief summary
732 F.2d 567 (1984)


CASE SYNOPSIS
Respondent government sought review of a judgment from the United States District Court for the Eastern District of Wisconsin, which granted petitioner a writ of habeas corpus and reversed petitioner's conviction on due process grounds.

CASE FACTS
The district court had granted petitioner a writ of habeas corpus and reversed his conviction on due process grounds. The district court had found that petitioner's conviction without proof of criminal intent violated his constitutional right to due process of law. Petitioner was convicted under Wis. Stat. § 100.26(3) of the Trade Practices Act for violating home improvement contractor regulations.

DISCUSSION
  • On appeal, the court disagreed with the district court, and reversed the grant of habeas corpus. 
  • The court found that the removal of intent from the offense did not amount to a shifting the burden of proof. 
  • Respondent government was still required to prove each element of the strict liability crime beyond a reasonable doubt. 
  • Also, § 100.26(3) did not raise a substantial question of vagueness. 
  • The regulations clearly enunciated that home improvement agreements required inclusion of starting and completion dates within the contract. 
  • Further, § 100.26(3) gave fair warning that failure to obey the regulations was a prohibited conduct. 
  • Section 100.26(3) did not infringe upon petitioner's due process rights.

CONCLUSION
The court reversed the district court's judgment, which granted petitioner a writ of habeas corpus and reversed his conviction on due process grounds. The statute that petitioner was convicted under was not impermissibly vague and gave fair warning of the proscribed conduct.


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