Strict Liability Offenses
Cannot use defense of Mistake of Law or Mistake of Fact.
Citation: Staples v. United States, Supreme court of the United States, U.S.
, S. Ct. 1793, 128 L.Ed.2d 608., (1994)
Key Facts: Petitioner was indicted for unlawful possession of an unregistered machinegun in violation of a statute. When in trial, the agents testified with just one pull of the trigger the gun shot more than one round. The petitioner testified that while in his possession the gun had never been used by him. He argued that his ignorance of any automatic firing capability should shield him from being prosecuted. He then requested the jury be instructed that it must be proved beyond a reasonable doubt that the defendant knew the gun would fire fully automatic, but the request was rejected.
Procedural History/Issue: The district court convicted and sentenced the petitioner to 5yrs probation and a $5,000 fine. The court of appeals affirmed the judgment.
Issue: Whether the legislature constructed the statute to require proof of an actors mens rea as to the nature of the weapon to be guilty under said statute?
Holding: dispensing with mens rea would require the defendant to have knowledge only of traditionally lawful conduct; a severe penalty is a further factor tending to suggest that congress did not intend to eliminate a mens rea requirement. The usually presumption that a defendant must know the facts that make his conduct illegal should apply.
Judgment: Judgment of the Court of Appeals was reversed and the case was remanded for further proceedings.
Reasoning/Rationale: The existence of a mens rea is the rule of, rather than the exception to the principles of Angelo-American criminal jurisprudence.
Concurring/Dissenting Opinions (if any): Stevens, Blackmun dissent- the guns in question are not that of ordinary usage...