Law School Case Brief
United States v. Plaza Health Labs. - 3 F.3d 643 (2d Cir. 1993)
In criminal prosecutions the rule of lenity requires that ambiguities in the statute be resolved in the defendant's favor.
On at least two occasions, Defendant Geronimo Villegas, co-owner and vice president of defendant Plaza Health Laboratories, Inc., a blood-testing laboratory in Brooklyn, New York, loaded containers of numerous vials of human blood generated from his business into his personal car, and drove to his residence at the Admirals Walk Condominium in Edgewater, New Jersey. Once at his condominium complex, Villegas removed the containers from his car and carried them to the edge of the Hudson River. Defendants were convicted of knowingly discharging pollutants into the Hudson River in violation of the Clean Water Act (CWA), 33 U.S.C.S. §§ 1251 et seq. Villegas appealed and contended that one element of the CWA crime, knowingly discharging pollutants from a "point source," was not established in his case. He argued that the definition of "point source," 33 U.S.C. § 1362(14), does not include discharges that result from the individual acts of human beings. Raising primarily questions of legislative intent and statutory construction, Villegas argued that at best, the term "point source" is ambiguous as applied to him, and that the rule of lenity should result in reversal of his convictions. The government cross-appealed, claiming the district court erred in its post-verdict grant of a judgment of acquittal on two counts of violating the knowing-endangerment provisions of the act.
Was the term "point source" ambiguous as applied to Villegas, thus, the rule of lenity should be resolved in Villegas’ favor?
The court held that the criminal provisions of the CWA had not clearly proscribed Villegas’ conduct because, as a human being, Villegas was not considered a "point source" for the discharge of pollutants and, as such, the CWA had not accorded him fair warning of the sanctions the law placed on that conduct. The court further held that under the rule of lenity, which stated that ambiguities in the statute were resolved in defendant's favor, mandated the reversal of the convictions.
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