Sunday, November 17, 2013

United States v. Feola case brief

United States v. Feola case brief summary
420 U.S. 671 (1975)


CASE SYNOPSIS
The respondent was convicted by a district court of conspiracy under 18 U.S.C.S. § 371 to commit an offense violative of 18 U.S.C.S. § 111, an assault upon a federal officer while the officer was engaged in the performance of his duties. The United States Court of Appeals for the Second Circuit reversed the conspiracy conviction. The Court granted the government's petition for a writ of certiorari.

CASE FACTS
The respondent was convicted by the district court of conspiracy under 18 U.S.C.S. § 371 to commit an offense violative of 18 U.S.C.S. § 111, an assault upon a federal officer while the officer was engaged in the performance of his duties.

DISCUSSION

  • The court of appeals reversed the conspiracy conviction. 
  • The court granted the government's petition for a writ of certiorari. 
  • The court rejected the respondent's contention that the government had to show that he was aware that his intended victims were undercover federal agents if it was to successfully prosecute him for conspiring to assault federal agents. 
  • The court held that where knowledge of the facts that gave rise to federal jurisdiction was not necessary for conviction of a substantive offense that embodied a mens rea requirement, such knowledge was equally irrelevant to questions of responsibility for conspiracy to commit that offense. 
  • The court noted an exception to the rule in the infrequent situation in which reference to the knowledge of the parties to an illegal agreement was necessary to establish the existence of federal jurisdiction.

CONCLUSION
The court reversed the judgment of the court of appeals, which reversed the respondent's conspiracy conviction. The court held that where knowledge of the facts that gave rise to federal jurisdiction was not necessary for conviction of a substantive offense that embodied a mens rea requirement, such knowledge was equally irrelevant to questions of responsibility for conspiracy to commit that offense.

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