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Criminal Law Keyed to Weaver
Staples v. United States
Citation:
511 U.S. 600 (1994)ProfessorScott Caron
CaseCast™ – "What you need to know"
Facts
The police, upon executing a search warrant of Staples’s home, found among other things an AR-15. An AR-15 is the civilian model of the well known military rifle, the M-16. The AR-15 is a semiautomatic rifle while the M-16 has a switch that allows the operator to switch from semiautomatic to full automatic modes. Because both weapons are so similar, most parts are interchangeable. Staples’s AR-15 had the switch from the M-16 to allow the weapon to fired as a semiautomatic or full automatic firearm. Additionally, the piece on the AR-15 to prevent such an easy transition to a fully automatic firearm by simply installing the M-16 switch was filed down. Officers tested the firearm and it fired as a machine gun.
At trial Staples testified that the firearm never fired fully automatic and stated it only fired as a semiautomatic and even imperfectly at that, as Staples testified he often had to manual eject the spent casing and chamber the new one. Staples contended that he is not criminally liable because he did not have knowledge of the rifle’s ability to be fired as fully automatic. The judge disagreed instructing the jury that the Government did not have to prove that the defendant knew that the rifle possessed every characteristic which subjects it to the regulation, it is enough that the Government proves that Staples knew he was dealing with a dangerous device of a type that would alert a normal person to the likelihood of regulation.
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