The definition of the elements of a criminal offense is entrusted to the legislature, particularly in the case of federal crimes, which are solely creatures of statute.
A restaurant owner was convicted in a Federal District Court of violating 7 USCS 2024(b), which provides that "whoever knowingly uses, transfers, acquires, alters, or possesses coupons or other authorization cards in any manner not authorized by [the statute] or the regulations" is subject to a fine and imprisonment, for having purchased food stamps from an undercover Department of Agriculture agent for substantially less than their face value. A jury trial ensued and defendant requested a "specific intent" instruction where the government would have been required to prove that defendant knowingly violated the law. The district court rejected this instruction and defendant was found guilty. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed, rejecting the defendant's contention that the District Court erred in refusing to instruct the jury that "specific intent" is required in a prosecution under 7 USCS 2024(b) (735 F2d 1044).
Was the conviction proper?
The Supreme Court held that absent a contrary purpose, the statutory rule of lenity applied since there was no express intent conveyed in the statute concerning a defendant's mental state. Accordingly, the Court reversed the conviction, holding that the statute required respondent to prove that defendant knowingly violated the law in purchasing food stamps.