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Staples v U. S.
S. Ct. U.S. 1994
Author:- Sam Biers
Relevant Facts: Df’s house was searched and a weapon was found that would fire more than one round of ammunition for each pull on the trigger. The metal stop on the weapon had been filed away and the M-16 selector switch had been installed to enable the firing to be continuous. BATF agents tested the weapon and it shot more than one per pull. Df testified the weapon had never fired properly when he had possession, let alone automatically.
Legal Issue(s): Whether the statute requires proof that the df knew of the characteristics of the gun under the Act?
Court’s Holding: In this case mens rea is required in that the df must have known the characteristics of the gun.
Procedure: Convicted and sentenced to five yrs probation/$5000. Ct. App. affirmed. Reversed.
Law or Rule(s): It is unlawful for any person to possess a machinegun that is not properly registered with the Fed. Gov’t. The required mental state for a federal crime is determined by the construction of the statute and inference of the intent of Congress.
Court Rationale: This statute is silent, so it must be construed in light of the background rule under the common law. Although inherently dangerous public welfare cases are capable of eliminating mens rea as an element to the offense, not all guns are dangerous. Guns can be owned in perfect innocence. Some guns fall outside the categories of machine guns, artillery piecs, and have been traditionally accepted as lawful possessions. Df must have knowledge of the characteristics of the gun itself to be guilty under the Act. Otherwise cars could be construed as inherently dangerous and susceptible to Congressional legislation The potential of a harsh sentence also begs the conclusion that the Act requires a showing of mens rea and not simply strict liability. The df must know the facts that make his conduct illegal.
Plaintiff’s Argument: The nature and purpose of the Act suggest that mens rea does not apply to this case. All guns are dangerous devices that put gun owners on notice that they must determine at their hazard whether their gun falls under the Act.
Defendant’s Argument: Df had no knowledge of the characteristics of the gun other than it would not fire properly under normal conditions.
Incongruous-conflicting , contradictory