A defendant cannot avoid prosecution by simply claiming that he had not brushed up on the law.
A case was filed against defendant for violation of 18 U.S.C.S. § 2320, due to his sale of counterfeit watches. He was convicted by the district court for trafficking in counterfeit goods. Defendant appealed to the United States Court of Appeals for the Fifth Circuit, alleging that the district court erred in denying his motion to dismiss and refusing to instruct the jury that defendant could not be convicted if he did not have the purpose to disobey or disregard the law.
Was the conviction proper?
The court affirmed the conviction, holding that the statute itself clearly set forth the elements of the crime and the mental state required for each element, requiring that defendant intentionally deal in goods and knowingly use a counterfeit mark in connection with those goods. The court further concluded that there was no ambiguity in the statutory language and that nothing in the statute suggested that any other mental state was required for conviction. Accordingly, ignorance of the law was not a valid defense.