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

  • Staples bought a used gun. Turns out it was an automatic machine-gun.
    • Possession of the weapon was a violation of the National Firearms Act.
      • The gun had a metal thingee that prevented it from firing automatically, but someone had filed it down.
    • Staples claimed he had no idea that the gun could fire automatically.
  • At Trial, Staples requested a jury instruction that he couldn’t be found guilty unless there was proof that he knew the gun could fire automatically. The Trial Judge refused to issue the instruction.
    • Looking at the Statute, the judge found that it did not require knowledge (aka mens rea), but that it was a strict liability crime.
  • The Trial Court convicted Staples of possessing an illegal firearm. He appealed.
  • The Appellate Court affirmed. He appealed.
  • The US Supreme Court reversed.
    • The US Supreme Court noted that the Statue was silent on whether or not mens rea was a required element.
    • The Court found that strict liability for criminal offenses is generally disfavored, and the courts are to assume that there is a mens rea requirement unless the Statute explicitly says there isn’t.
    • The prosecutor argued that “public welfare” and “regulatory” offenses generally do have strict liability (for example, parking tickets), and that this Statute was similar, because people running around machine guns was a threat to public welfare.
      • Many crimes involving “possession of dangerous devices of a character that places the possessor in responsible relation to a public danger” have strict liability.
      • The Court rejected that argument because the 2nd Amendment and the historical common law have granted unfettered rights to gun owners.
        • Conversely, the Court noted that if Staples had been arrested for possessing a grenade, then that would be a strict liability crime.