Sunday, November 17, 2013

Staples v. United States case brief

Staples v. United States case brief summary
511 U.S. 600 (1994)


CASE SYNOPSIS
Petitioner appealed from the order of the United States Court of Appeals for the Tenth Circuit that convicted and sentenced him for unlawful possession of an unregistered machinegun under the National Firearms Act, 26 U.S.C.S. § 5861(d).

CASE FACTS
Petitioner was indicted for unlawful possession of an unregistered machinegun in violation of the National Firearms Act (Act), 26 U.S.C.S. § 5861(d) following the recovery of a weapon from petitioner's home. At trial, petitioner testified that the weapon had never fired automatically when it was in his possession, and that he was ignorant of the weapon's automatic firing capability. The district court rejected petitioner's contention that § 5861(d)contained a mens rea requirement. Petitioner was convicted and sentenced for the offense, and the court of appeals affirmed.

DISCUSSION

  • The court granted certiorari and reversed and remanded, holding that to obtain a conviction under the Act, the government was required to prove that petitioner knew of the features of his weapon that brought it within the scope of the Act. 
  • The court noted that the silence as to the mens rea requirement in § 5861(d) did not suggest a congressional intent that such requirement be eliminated. 
  • The court noted that the potentially harsh penalty attached to a violation of § 5861(d) provided further support for the proposition that a mens rea requirement existed.

CONCLUSION
The court granted certiorari and reversed and remanded the order of the court of appeals that convicted and sentenced petitioner for unlawful possession of an unregistered machinegun under the National Firearms Act (Act) because the government did not prove that petitioner knew that the features of his weapon brought it within the prohibitions of the Act.

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