Bryan v. United States

Brief Fact Summary.

Bryan appeals his conviction of illicitly selling firearms in violation of the federal firearms statute because he did not “willfully” sell the firearms as delineated in the statute.

Synopsis of Rule of Law.

An individual can be convicted of “willfully” violating a federal statute if the individual knows that his actions are unlawful.

Facts.

Bryan was convicted of illicitly selling firearms in violation of the federal firearms statute. Bryan argued that he could not be convicted of “willfully” violating the federal firearms statute because he was not aware of the federal licensing requirements for firearms dealers.

Issue.

Whether an individual can be convicted of “willfully” violating federal licensing requirements for selling firearms if the individual did not know that his actions violated the federal statute.

Held.

Yes. A person does not have to know which individual statute he was violating in order for his actions to be considered “willful.”

Dissent.

(Scalia, J). The mens rea requirement of the statute is ambiguous because the definition of “willful” is determined differently within every statute. Therefore, each statute must state their definition of “willfully” that would satisfy the mens rea requirement and must also state whether or not ignorance of the law would overturn conviction under the statute.

Discussion.

A defendant satisfies a “willful” act under the mens rea requirement if the defendant acted with the knowledge that his actions were unlawful. Bryan knew that his actions violated the law, despite which subsection of the law was violated. Ignorance of the law cannot overcome a defendant’s conviction for violating a federal statute.