Morissette v. United States facts for kids
Quick facts for kids Morissette v. United States |
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Argued October 9–10, 1951 Decided January 7, 1952 |
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Full case name | Morissette v. United States |
Citations | 342 U.S. 246 (more)
72 S. Ct. 240; 96 L. Ed. 288; 1952 U.S. LEXIS 2714
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Prior history | Cert. to the United States Court of Appeals for the Sixth Circuit |
Holding | |
Mere omission of any mention of intent from the criminal statute was not to be construed as the elimination of that element from the crimes denounced, and that where intent was an element of the crime charged, its existence was a question of fact to be determined by the jury. | |
Court membership | |
Case opinions | |
Majority | Jackson, joined by unanimous |
Minton took no part in the consideration or decision of the case. |
Morissette v. United States was an important case decided by the U.S. Supreme Court in 1952. This case helped explain the idea of "criminal intent" in the law. It talked about two main types of crimes. Some crimes require a person to have a certain thought or intention, like knowing they are doing something wrong. Other crimes do not need this kind of intent.
The case was about a man named Morissette. He collected old bomb casings from an Air Force practice range. He thought these casings had been left behind and were no longer wanted. He then sold them for $84.00. However, he was charged with "knowingly" taking government property. Morissette argued that he honestly believed the casings were abandoned. The Supreme Court decided that his conviction was wrong. They said that for many crimes, a person must intend to do something against the law.
The Court explained that in most legal systems, for a harmful act to be a crime, there must be some "mental element." This means a person usually needs to have an "evil-meaning mind" (bad intent) along with an "evil-acting hand" (doing the bad act). When states wrote down their laws, even if they didn't specifically mention "intent," it was usually understood that intent was a necessary part of the crime.
However, the Court also pointed out a different group of laws called "public welfare offenses." These are different from traditional crimes. Public welfare offenses do not usually involve harming people or property directly. Instead, they are about things like not being careful when the law requires it. Examples include rules about public health, building safety, or food and drug safety. For these types of offenses, a person does not need to have a specific bad intent or knowledge to be found guilty.
The Story of the Case
The person involved in this case was a man named Morissette. He worked part-time dealing with scrap metal. One day, he went onto an Air Force bombing range in Oscoda, Michigan. He collected old bomb casings that had been there for many years.
Morissette then sold these casings at a junk market. He made $84 from the sale. Because of this, he was accused of breaking a law. This law, 18 U.S.C. § 641, made it a crime to "knowingly convert" government property. To "convert" means to take something and use it as your own.
Morissette admitted that he took the casings. But he said his only defense was that he truly believed the casings were abandoned. He thought they were just trash that no one wanted anymore. So, he argued that he didn't commit a crime by taking them.
What Happened in Court
During the trial, the judge told the jury what the law meant. The judge disagreed with Morissette's defense. The judge thought that the law meant Morissette only needed to have "intentionally exercised dominion over the property." This means the judge believed Morissette was guilty just because he took the government property on purpose.
The jury was allowed to find Morissette guilty just for taking the property. They did not have to consider if he believed the casings were abandoned. They also were not allowed to think about whether he knew it was government property. If this understanding of the law was correct, it would mean that a person could be guilty without meaning to do anything wrong. This is called a "strict liability" crime.
The first court that heard Morissette's appeal agreed with the trial court. But then, the case went to the Supreme Court. The Supreme Court is the highest court in the United States. They decided to hear the appeal and changed the decision of the lower courts.
The Supreme Court's Decision
The Supreme Court said that to be guilty, Morissette had to know that the property he took was not abandoned. He had to know that it was still government property. Justice Robert Jackson wrote the opinion for the Court. All the judges agreed with him.
Justice Jackson stressed how important "criminal intent" is in the legal system. He famously wrote that a crime usually happens when an "evil-meaning mind" (bad intent) works with an "evil-doing hand" (the bad action). This means that for many crimes, a person must intend to do something wrong.
However, the Supreme Court also made an important point. They said that some laws are different. These are laws about "public welfare offenses." These laws are not like traditional crimes. They don't always involve direct harm to the government, people, or property. Instead, they are about things like not being careful when the law requires it.
Examples of public welfare offenses include laws about public health, building safety rules, or food and drug safety. For these types of laws, a person does not need to have a specific bad intent or knowledge to be found guilty. This is because these laws are meant to protect everyone's safety and well-being.
Andrew J. Transue was the lawyer who represented Morissette in this case.
See also
- List of United States Supreme Court cases, volume 342