United States v. Park

421 U.S. 658, 95 S. Ct. 1903 (1975)

 

RULE:

A single instruction to a jury may not be judged in artificial isolation, but must be viewed in the context of the overall charge.

FACTS:

A national retail grocery retailer and the corporate officer, who served as the chief executive officer of the retailer, were charged with violating 21U.S.C.S. § 331(k), after an inspection by the Food and Drug Administration revealed filthy conditions in the retailer's warehouses. The retailer pleaded guilty. The corporate officer pleaded not guilty. After a jury trial, the corporate officer was found guilty on all counts and sentenced to pay fines. The appellate court reversed the corporate officer's convictions because it found the jury instructions erroneous.

ISSUE:

Are jury instructions that adequately describe the conditions for responsibility, together with failure to give sua sponte instructions, erroneous?

ANSWER:

No.

CONCLUSION:

The court held that the jury's attention was properly focused on the corporate officer's authority over the conditions that formed the basis of the violations. The main issue for determination was the corporate officer's accountability. The instructions to the jury were not misleading and contained an adequate statement of the law. There was no basis to conclude that the failure of the court to give specific instructions sua sponte was plain error or a defect affecting the corporate officer's substantial rights under Fed. R. Crim. P. 52(b).

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