United States v. Baker

Brief Fact Summary.

Baker (Defendant) was convicted of trafficking in counterfeit watches and appealed, arguing that he was unaware that the conduct was illegal.

Synopsis of Rule of Law.

Mistake of law is not a defense

Facts.

Before 1984, knowingly trafficking in counterfeit goods was subject to civil penalties, but was not a criminal offense. Congress enacted the Trademark Counterfeiting Act in 1984 and made it a crime. Defendant knowingly and intentionally sold counterfeit Rolex watches and was convicted of violating the law. Defendant appealed, claiming that he did not know that the law had been passed.

Issue.

Is mistake or ignorance of the law a valid defense to a crime?

Held.

(Reavley, J.) No. Mistake of law is not a defense. Criminal law does not require knowledge that conduct is illegal. A defendant cannot escape prosecution by claiming ignorance of the law. Defendant’s conduct satisfied the required mental state because he knew that he was dealing in counterfeit goods. His knowledge of the law is immaterial. Affirmed.

Discussion.

Mistake of fact can be a defense when a defendant is unaware of or mistaken about the factual conditions specified under a criminal law. Ignorance of what conditions are specified under the law itself is not a defense.