Staples v. United States

Summary

The Supreme Court held that conviction for possession of an unregistered machinegun under 26 U.S.C. § 5861(d) requires the Government to prove beyond a reasonable doubt that the defendant knew of the weapon's characteristics that brought it within the Act's definition of a firearm. Applying the background common-law presumption favoring mens rea, the Court rejected the Government's public welfare offense theory because guns, unlike narcotics or hand grenades, are traditionally and widely owned lawfully, and the felony-grade penalty of up to ten years further counsels against eliminating mens rea. The Court emphasized that its holding is narrow, resting on a commonsense evaluation of the regulated item and the expectations individuals may legitimately have in dealing with it, and it reversed and remanded. Justice Ginsburg, concurring in the judgment, would ground the result in the indictment's proper charge of knowing machinegun possession versus the defective jury instruction; Justice Stevens, dissenting, joined by Justice Blackmun, would affirm on the ground that § 5861(d) is a public welfare offense requiring only knowledge of possessing a dangerous device likely to be regulated.