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Criminal Law Keyed to Ohlin
Staples v. United States
Citation:511 U.S. 600 (1994)
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- Procedural Posture & History: Shares the case history with how lower courts have ruled on the matter.
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- Facts: What are the factual circumstances that gave rise to the civil or criminal case? What is the relationship of the Parties that are involved in the case. Review the Facts of this case here:
Local police were executing a search warrant at Staples’ home when they discovered an AR-15 rifle, a civilian version of the military’s M-16 rifle. Unless modified, the AR-15 is a semiautomatic weapon while the M-16 is a selective fire rifle that allows the operator, by rotating a selector switch, to choose semiautomatic or automatic fire. Staples’ rifle, however, had been modified to be capable of fully automatic fire.
Staples was charged with unlawful possession of an unregistered machinegun in violation of § 5861(d) of the National Firearms Act. At trial, it was undisputed that the rifle was not registered as required by § 5861(d). However, Staples testified that the rifle never fired automatically when it was in his possession and he was unaware that it was modified. He argued that his ignorance of any automatic firing capability should have shielded him from criminal liability for his failure to register the weapon. The District Court rejected this, and told the jury that Staples did not need to know that he was dealing with a rifle possessing every characteristic that subjects it to regulation, but rather it “would be enough to prove he knows that he is dealing with a dangerous device of a type as would alert one to the likelihood of regulation.”
Staples was convicted and sentenced to five years’ probation and a $5,000 fine.
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