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Citation. 511 U.S. 600, 114 S. Ct. 1793, 128 L. Ed. 2d 608, 1994 U.S. 3773.
Brief Fact Summary. This case arose after agents of the Bureau of Alcohol, Tobacco and Firearms executed a search warrant at the Petitioner, Staple’s (Petitioner) home and discovered a modified, automatic, AR-15 rifle that had not been registered in the National Firearms and Transfer Record maintained by the Secretary of the Treasury, as required by the National Firearms Act (the Act).
Synopsis of Rule of Law. Where dispensing with mens rea would require the defendant to have knowledge only of traditionally lawful conduct, a severe penalty is a further factor tending to suggest that Congress did not intend to eliminate a mens rea requirement.
The AR-15 rifle that was taken by Alcohol Tobacco and Firearms agents had been modified to include several M-16 parts. The inclusion of the M-16 parts allowed the firearm in question to become interchangeable between semi-automatic, as was its intended use and automatic. The Petitioner testified that the firearm had never been operated automatically while in his possession. Further, the Petitioner testified that his ignorance of any automatic firing capability should have shielded him from criminal liability for failure to register the weapon. The District Court rejected the Petitioner’s proposed jury instruction to that effect and the Petitioner was subsequently sentenced to five years’ probation and a $5,000 fine. The Court of Appeals affirmed that decision. Furthermore, the statute at issue in this case is silent as to the mens rea required for a violation. Issue.
Are all guns, whether or not they are statutory firearms, dangerous devices that put gun owners on notice that they must determine at their hazard whether their weapons come within the scope of the Act?