Facts of the Case
“The Firearms Owners’ Protection Act (FOPA) prohibited anyone from “willfully” dealing in firearms without a federal license. Defendant Sillasse Bryan was on trial in federal district court for unlicensed dealing, and the evidence at trial adequately proved that he was dealing in firearms and that he knew his conduct was unlawful, but there was no evidence that he was aware of the federal licensing requirement. The trial judge refused to instruct the jury that he could be convicted only if he knew of the federal licensing requirement, instructing, instead, that a person acted “willfully” if he acted with the bad purpose to disobey or disregard the law, but that he need not be aware of the specific law that his conduct may be violating. The jury convicted Bryan of willfully dealing in firearms without a federal license. On appeal, the United States Court of Appeals for the Second Circuit affirmed, concluding that the instructions were proper and that the Government had elicited “ample proof” that Bryan had acted willfully.”
Can private parties who claim they have suffered economic harm from enforcement of the Endangered Species Act sue to reverse regulation?
“No. In a 6-3 opinion delivered by Justice John Paul Stevens, the Court held that the term “willfully” in section 924(a)(1)(D) requires proof only that the defendant knew his conduct was unlawful, not that he also knew of the federal licensing requirement. Justice Stevens wrote for that court that “the willfulness requirement of [section 924(a)(1)(D)] does not carve out an exception to the traditional rule that ignorance of the law is no excuse