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United States v. MacDonald & Watson Waste Oil Co.
United States Court of Appeals (1991)
Defendant: D'Allesandro; the defendant was the owner and president of MacDonald waste moving company. Defendant's company was moving solid wastes to Watson Waste Oil Plant which did not have a permit to hold such type of waste products. The defendant was charged for violation of RCRA, a statue which holds people liable if they "knowingly" violate its terms. The trial judge gave jury the instructions that if the defendant is the responsible corporate officer, he is liable for the actions of his company. But the defendant argued that these instructions were wrong because he did not have any knowledge of the violations. The jury convicted the defendant.
Issue: Is actual knowledge of the defendant needed in order to convict him for violating RCRA?
Holding: Yes
Legal Reasoning: The court held that unlike United States v. Dotterwech and United States v. Park, this case involved a felony statue where there was a possible 5 to 10 year imprisonment sentence. The court held that since the statue clearly stated that knowledge is required, that should be it. The court ruled that in order for the defendant to be convicted under the given statue, his actual knowledge of the violation must be proven. Reversed and remanded.