Law School Case Brief
Bryan v. United States - 524 U.S. 184, 118 S. Ct. 1939 (1998)
Unless the text of the statute dictates a different result, the term "knowingly" merely requires proof of knowledge of the facts that constitute the offense.
The Firearms Owners' Protection Act (FOPA) prohibited anyone from "willfully" dealing in firearms without a federal license. Defendant Sillasse Bryan was on trial in federal district court for unlicensed dealing, and the evidence at trial adequately proved that he was dealing in firearms and that he knew his conduct was unlawful, but there was no evidence that he was aware of the federal licensing requirement. The trial judge refused to instruct the jury that he could be convicted only if he knew of the federal licensing requirement, instructing, instead, that a person acted "willfully" if he acted with the bad purpose to disobey or disregard the law, but that he need not be aware of the specific law that his conduct may be violating. The jury convicted Bryan of willfully dealing in firearms without a federal license. On appeal, the United States Court of Appeals for the Second Circuit affirmed, concluding that the instructions were proper and that the Government had elicited "ample proof" that Bryan had acted willfully.
Was Bryan's conviction proper?
The Supreme Court of the United States affirmed the appellate court's order that affirmed Bryan's conviction for willfully dealing in firearms without a federal license. The Court ruled that the Government was not required to prove Bryan knew that there was a federal law that prohibited dealing in firearms without a federal license. The Court found that a willful act was one undertaken with a bad purpose. The knowledge requisite to knowing of a violation of a statute was a factual knowledge as distinguished from knowledge of the law. The Court held that there was sufficient willfulness to support the conviction because Bryan dealt in firearms and knew his conduct was unlawful. The law did not carve out an exception to the rule that ignorance of the law was no excuse.
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