United States v. Cordoba Hincapie

Citation825 F. Supp. 485, 1993 U.S. Dist. 9504.

Brief Fact Summary. This case explains the historical perspective behind the concept of mens rea and also highlights the public policies behind this concept. No exact factual scenario was presented by either of the two excepts of this case in the Dressler book. This case is merely offered by way of background material for subsequent cases involving more complex issues of mens rea.

Synopsis of Rule of Law. The term mens rea has two competing meanings. On one hand, the broad view of mens rea simply means “guilty mind.” Under this definition, an individual will be found guilty for any criminal act (actus reus) that he committed while having any morally culpable or blameworthy state of mind. On the other hand, the narrow view of mens rea provides that an individual is not guilty of an offense, even if he had a guilty state of mind, where the individual’s state of mind does not match the mental state specified in the definition of the charged crime.

Discussion. This case more narrowly discusses strict liability offenses in relation to mens rea. The District Court for the Eastern District of New York stated that strict-liability offenses are those that involve the imposition of a relatively small fine and probably not imprisonment. These strict-liability crimes are also known as offenses against the public welfare and include: (1) minor violations of traffic laws, pure food laws, the anti-narcotics laws, sanitary, building and factory laws as well as the offense of (2) statutory rape. Under these strict liability offenses, an individual will be convicted, and usually incur a light fine or penalty, no matter what their mental state at the time of the commission of the crime. Strict liability offenses are also found in cases involving mistake-of-fact, including a defense to a charge of statutory rape where the individual charged with the offense alleges that he believed the victim to be over the age of consent.