Bryan v. United States

Brief Fact Summary.

Bryan (defendant) had several individuals travel out of state to Ohio, to acquire firearms, and bring them back to him in New York. He would then file off the serial number on the firearms and sell them. He was convicted of “willfully” selling the firearms in violation of the federal statutes.

Synopsis of Rule of Law.

For a defendant to be convicted of “willfully” committing a crime he must commit the crime while having knowledge that the actions he is taking are unlawful.

Facts.

Bryan (defendant) ordered individuals to travel out of state to Ohio in order to acquire firearms and bring them back to him in New York. He would then file off the serial number on the firearms and sell them. He was convicted of “willfully” selling the firearms in violation of various federal statutes. Bryan contended that he could not “willfully” have committed the crime because he was unaware of the regulations regarding licensing of firearm dealers. Bryan sought a write of certiorari from the Supreme Court arguing his conviction should be overturned because his actions did not meet the definition of “willful”.

Issue.

Whether Bryan can be convicted of violating the firearm statutes for “willfully” selling firearms without evidence of his knowledge of the federal licensing requirement set out in the statute.

Held.

Yes, the defendant does not need to be aware of any specific statute that he may be violating to constitute a “willful” violation.

Dissent.

The word willfull is open to several different interpretations under the law and has never been easy defined, which makes the statute and its mens rea requirement unenforceable. The statute must expressly state whether ignorance of the law may be used as a defense and until that point, words such as “willfully” will render a statute’s mens rea requirement generally unenforceable.

Discussion.

The defendant does not need to be aware that there is a specific statute that he is violating to constitute a “willful” violation, all that is needed to satisfy the mens rea for a crime is that the defendant knows that his actions are unlawful. Knowledge of any specific laws is not needed. Here, Bryan knew that his actions where unlawful and it is irrelevant that he did not know what specific law he was violating.