Staples v. United States, 511 U.S. 600 (1994)

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certiorari to the united states court of appeals for the tenth circuit

No. 92-1441. Argued November 30, 1993—Decided May 23, 1994

The National Firearms Act criminalizes possession of an unregistered

"firearm," 26 U. S. C. 5861(d), including a "machinegun," 5845(a)(6), which is defined as a weapon that automatically fires more than one shot with a single pull of the trigger, 5845(b). Petitioner Staples was charged with possessing an unregistered machinegun in violation of 5861(d) after officers searching his home seized a semiautomatic rifle— i. e., a weapon that normally fires only one shot with each trigger pull— that had apparently been modified for fully automatic fire. At trial, Staples testified that the rifle had never fired automatically while he possessed it and that he had been ignorant of any automatic firing capability. He was convicted after the District Court rejected his proposed jury instruction under which, to establish a 5861(d) violation, the Government would have been required to prove beyond a reasonable doubt that Staples knew that the gun would fire fully automatically. The Court of Appeals affirmed, concluding that the Government need not prove a defendant's knowledge of a weapon's physical properties to obtain a conviction under 5861(d).

Held: To obtain a 5861(d) conviction, the Government should have been required to prove beyond a reasonable doubt that Staples knew that his rifle had the characteristics that brought it within the statutory definition of a machinegun. Pp. 604-619. (a) The common-law rule requiring mens rea as an element of a crime informs interpretation of 5861(d) in this case. Because some indication of congressional intent, express or implied, is required to dispense with mens rea, 5861(d)'s silence on the element of knowledge required for a conviction does not suggest that Congress intended to dispense with a conventional mens rea requirement, which would require that the defendant know the facts making his conduct illegal. Pp. 604-606. (b) The Court rejects the Government's argument that the Act fits within the Court's line of precedent concerning "public welfare" or "regulatory" offenses and thus that the presumption favoring mens rea does not apply in this case. In cases concerning public welfare offenses, the Court has inferred from silence a congressional intent to dispense with conventional mens rea requirements in statutes that regulate potentially harmful or injurious items. In such cases, the Court has reasoned

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