United States v. Feola

Facts of the Case

Respondent was convicted by the district court of conspiracy under 18 U.S.C.S. § 371 to commit an offense violative of 18 U.S.C.S. § 111, an assault upon a federal officer while the officer was engaged in the performance of his duties. The appellate court affirmed the convictions on the substantive charges, but reversed the conspiracy convictions, holding that while respondent’s knowledge of the victims’ official status was not required to be established as to the substantive charge, nevertheless the failure to instruct the jury that such knowledge must be proved to convict on the conspiracy charge constituted plain error.  The Supreme Court of the United States reversed the appellate court’s judgment.

Question

Is the knowledge that an intended assault victim is a federal agent an essential element in the crime of conspiracy to assault a federal officer?

CONCLUSION

No. Justice Harry A. Blackmun delivered the opinion of the 7-2 majority. The Court held that, given the legislative history of the statute, Congress clearly intended it to afford “maximum protection” to federal officers. This purpose was best satisfied with a looser understanding of intent. The Court held that this ruling was not unfair to the defendant because it did not make a previously legal action illegal. Intent to assault is criminal, regardless of the intended victim. The Court also held that the burden for proving conspiracy was not any higher than the burden for proving the element of the crime itself.Justice Potter Stewart wrote a dissent where he argued that the precedent established by state laws makes the knowledge of an officer’s identity an essential element of the crime of assaulting one. Without such knowledge, the crime should be treated as an assault on a private citizen. He also argued that the statute’s specification regarding an assault on a federal agent during the “performance of his official duties” requires that the perpetrator be aware of the federal agent’s official status. Justice William O. Douglas joined the dissent.

Case Information

  • Citation: 420 US 671 (1975)
  • Argued: Nov 19, 1974
  • Decided Mar 19, 1975Granted: Apr 15, 1974