Bryan v. United States

Brief Fact Summary.

Defendant was convicted of willfully selling firearms in violation of federal statutes. Defendant argued that he could not be convicted of willfully selling the firearms because he did not know about the federal licensing requirement expressed in the statute.

Synopsis of Rule of Law.

Defendant was convicted of willfully selling firearms in violation of federal statutes. Defendant argued that he could not be convicted of willfully selling the firearms because he did not know about the federal licensing requirement expressed in the statute.

Facts.

After selling firearms, Bryan (Defendant) was convicted of willfully selling firearms in violation of federal statutes. Defendant had people purchase the firearms for him in Ohio and bring them back to him in New York. After these people brought back the firearms to him in New York, Defendant filed off the serial numbers from the firearms and sold them. At trial, Defendant argued that he couldn’t be convicted of willfully selling the firearms because he did not know the precise legislation for the federal licensing of firearm dealers. Claiming that he did not willfully sell the firearms as required by the federal statute, Defendant petitioned to the United States Supreme Court to overturn his conviction.

Issue.

If there is no evidence to support that a person had knowledge of the federal licensing requirement expressed in the statute, can a person be convicted of willfully selling firearms as prohibited by the statute?

Held.

Yes. Even if there is no evidence to support that a person had knowledge of the federal licensing requirement expressed in the statute, a person can be convicted of willfully selling firearms as prohibited by the statute. Here, Defendant knew his actions were illegal no matter which subsection of the statute his actions were violating. Therefore, The United States Supreme Court upheld Defendant’s conviction for willfully selling firearms.

Dissent.

Because the statute and its mens rea requirement are ambiguous, the statute is unenforceable. Because the word willfully has so many different meanings under the law and has caused so many problems with different laws and convictions, the word should be defined in each statute. Each statute should express whether ignorance of the law is considered a defense. The Legislature should draft statutes that are clearer with respect to mens rea requirements to avoid problems of interpretation. 

Discussion.

To satisfy the mens rea requirement for willful conduct, a person must act with knowledge that his conduct is unlawful. A person does not need to have knowledge of the specific law he or she is breaking in order for his conduct to be break that law. As such, ignorance of the law is almost never a defense to committing a crime.