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Morisette v. United States

(1952)

Supreme Court of the United States - 342 U.S. 246

tl;dr:

The mere fact that a statute fails to mention a mens rea requirement does not mean that it should be read to impose strict liability.

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Facts & HoldingMorisette v. United States case brief facts & holding

Facts:The defendant was convicted of converting government property under a...

Holding:The Court held that the mere lack of an intent...

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Majority opinion, author: Mr. Justice Jackson
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The Supreme Court ruled that a culpable state of mind is necessary in all federal crimes, and that the concept of "crime" requires both a guilty mind and a guilty act. While regulations for public welfare offenses do not require intent as a necessary element, penalties for such offenses are relatively small and conviction does not cause significant damage to an offender's reputation. The power to imprison for unintended violations remains an open question, but state courts have upheld the power to penalize violations of regulations prescribed by statutes, whether intentional or not, with moderate fines. The Supreme Court has recognized that in cases involving regulatory offenses, where the emphasis of the statute is on achieving social betterment rather than punishing crimes, the question of legislative intent is to be construed by the court.

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Morisette v. United States

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