United States v. Plaza
Health Laboratories, Inc. case brief
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3 F.3d 643 (2d. Cir. 1993)
CASE SYNOPSIS: Defendant
and the government both appealed the judgment of the United States
District Court for the Eastern District of New York, which convicted
defendant of knowingly discharging pollutants into a river in
violation of the Clean Water Act (CWA), 33 U.S.C.S. § 1251 et seq.,
and granted of a judgment of acquittal on two counts of violating the
knowing-endangerment provisions of the CWA.
FACTS: Defendant was convicted of knowingly discharging pollutants into the Hudson River in violation of the Clean Water Act (CWA), 33 U.S.C.S. § 1251 et seq. The district court granted a judgment of acquittal on two counts of violating the knowing-endangerment provisions of the CWA. Defendant and the government both sought review. On appeal, the court reversed the conviction and affirmed the judgment of acquittal. The court held that the criminal provisions of the CWA had not clearly proscribed defendant's conduct because as a human being he was not considered a "point source" for the discharge of pollutants and had not accorded him fair warning of the sanctions the law placed on that conduct. The court further held that under the rule of lenity, which stated that ambiguities in the statute were resolved in defendant's favor, mandated the reversal of the convictions.
CONCLUSION: The court reversed defendant's convictions for knowingly discharging pollutants and affirmed the judgment of acquittal. The court held that defendant's conduct was not proscribed by statutory prohibitions against water pollution, and that defendant was required to have the statutory ambiguities resolved in his favor.
FACTS: Defendant was convicted of knowingly discharging pollutants into the Hudson River in violation of the Clean Water Act (CWA), 33 U.S.C.S. § 1251 et seq. The district court granted a judgment of acquittal on two counts of violating the knowing-endangerment provisions of the CWA. Defendant and the government both sought review. On appeal, the court reversed the conviction and affirmed the judgment of acquittal. The court held that the criminal provisions of the CWA had not clearly proscribed defendant's conduct because as a human being he was not considered a "point source" for the discharge of pollutants and had not accorded him fair warning of the sanctions the law placed on that conduct. The court further held that under the rule of lenity, which stated that ambiguities in the statute were resolved in defendant's favor, mandated the reversal of the convictions.
CONCLUSION: The court reversed defendant's convictions for knowingly discharging pollutants and affirmed the judgment of acquittal. The court held that defendant's conduct was not proscribed by statutory prohibitions against water pollution, and that defendant was required to have the statutory ambiguities resolved in his favor.
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