Tuesday, December 2, 2014

Staples v. U.S. Case Brief Summary

Staples v. United States case brief summary

FACTS
The National Firearms Act makes it unlawful for any person to posses an automatic weapon without first registering it.  The statute is silent on mens rea requirement.  The defendant testified that he was ignorant of its firing capabilities.

HOLDING
1. To obtain a conviction the government should have been required to prove that petitioner knew of the features of his altered weapon making it auto that brought it w/in the scope of the stat. A gun is not the type of dangerous device that would alert one to the possibility of regulation.

2. The court noted that the silence as to the mens rea requirement did not suggest a congressional intent that such requirement be eliminated. The court noted that the potentially harsh penalty attached provided further support for the proposition that a mens rea requirement existed.

RULES
Absent an explicit statement by Congress, silence does not suggest that Congress dispensed with mens rea.

ANALYSIS
One way to distinguish this from international is that the toxic chemicals are inherently dangerous whereas with the gun on its own is not. You have to load bullets, turn off safety, etc.

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