Bryan v. United States

Brief Fact Summary.

Defendant petitioned the United States Supreme Court to overturn his conviction of “willfully” selling firearms in violation of various statutes.

Synopsis of Rule of Law.

An individual “willfully” commits a crime if he acts with the knowledge that his actions are unlawful.

Facts.

Bryan (Defendant) was convicted of “willfully” selling firearms in violation of various federal firearms statutes. Bryan had individuals go purchase firearms for him in Ohio and bring them back to him in New York, where he filed off the serial numbers and sold them. Bryan claimed that he could not be convicted of “willfully” selling the firearms as prohibited by the statute because he did not know of the specific legislation for the federal licensing of firearms dealers. Bryan petitioned the United States Supreme Court to overturn his conviction on this count because he believed he did not “willfully” sell the firearms as required by the statute.

Issue.

Whether an individual can be convicted of “willfully” selling firearms as prohibited by federal statutes if there is no evidence of his knowledge of the federal licensing requirement delineated in the statute.

Held.

Yes. Defendant’s conviction is affirmed. An individual “willfully” commits a crime if he acts with the knowledge that his actions are unlawful.

Dissent.

Scalia, J.
The statute and its mens rea requirement are ambiguous and thus generally unenforceable. The word “willfully” has so many different interpretations under the law that it has caused problems with many different statutes and different federal convictions. Each statute should state whether ignorance of the law is a defense, and until that happens, the arbitrary words used for mens rea requirements, such as “willfully” and “knowingly,” will continue to cause problems in the judicial system. Therefore, Congress should work on adapting the mens rea requirements contained within statutes to be more uniform and easily interpreted.

Discussion.

To fulfill the mens rea for a crime with a “willful” requirement, the individual must have “acted with knowledge that his conduct was unlawful.” Except for certain tax statutes, this does not mean that the individual had to be aware of the specific law that he is breaking in order to have done so willfully. Here, the statute at issue is not a tax statute, and Bryan knew what he was doing was wrong and against the law, no matter which subsection of the statute it was against.  Ignorance of the law is almost never a valid defense to the commission of a crime or tort.