Bryan v. United States case brief summary
524 U.S. 184 (1998)
FACTS
Defendant was convicted of “willfully” dealing in firearms without a federal license. Jury instruction was “with the bad purpose to disobey the law and that person not need be aware of the specific law conduct violates”
HOLDING
524 U.S. 184 (1998)
FACTS
Defendant was convicted of “willfully” dealing in firearms without a federal license. Jury instruction was “with the bad purpose to disobey the law and that person not need be aware of the specific law conduct violates”
HOLDING
must show the intent to do something that the law forbids. Evidence showed willful disregard of the law.
ANALYSIS
1. There was sufficient willfulness to support petitioner's conviction because he dealt in firearms and knew his conduct was unlawful. The prosecutor was not required to prove petitioner knew that there was a federal law that prohibited dealing in firearms without a federal license.
2. The defendant probably generally knew that the act he was doing illegal since he was known to filing off the serial numbers. Additionally the fact that he was using a strawman shows that he knew something illegal going on.
3. "The willfulness requirement does not carve out an exception to the traditional rule that ignorance of the law is no excuse; knowledge that the conduct is unlawful is all that is required."
RULES
ANALYSIS
1. There was sufficient willfulness to support petitioner's conviction because he dealt in firearms and knew his conduct was unlawful. The prosecutor was not required to prove petitioner knew that there was a federal law that prohibited dealing in firearms without a federal license.
2. The defendant probably generally knew that the act he was doing illegal since he was known to filing off the serial numbers. Additionally the fact that he was using a strawman shows that he knew something illegal going on.
3. "The willfulness requirement does not carve out an exception to the traditional rule that ignorance of the law is no excuse; knowledge that the conduct is unlawful is all that is required."
RULES
Willful Level of Mens Rea requires proof that ∆ knew that conduct was unlawful, he need not know of the actual law he is breaking.
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