RESPONDENT: John R. Park
LOCATION: Scott County Department of Social Services
DOCKET NO.: 74-215
DECIDED BY: Burger Court (1972-1975)
LOWER COURT: United States Court of Appeals for the Fourth Circuit
CITATION: 421 US 658 (1975)
ARGUED: Mar 18, 1975 / Mar 19, 1975
DECIDED: Jun 09, 1975
Allan A. Tuttle - for petitioner
Gregory M. Harvey - for respondent
Facts of the case
United States v. Park case study explains how the Supreme Court of the US ensured that the Food and Drug Administration (FDA) became able to lift the corporate confidentiality. One of the governmental petitions released after the case of the US v. Dotterweich questioned if the manager of a company or a company itself could be prosecuted based on the Federal Food, Drug, and Cosmetic Act. The grounds for that was the engagement of the adulterated and misbranded products into commerce between the states. The defendant in the case of the US v. Park was the CEO of Acme International John R. Park. He did not manage to comply with the mandate released by FDA to follow the conditions within his business legally sanitary. To be exact, Acme International Corporation, but not the respondent himself, has been declared guilty.
As the case brief explains, the judge decided that John R. Park was responsible for such conditions in his firm. He fostered these issues in spite of the rules developed by the Federal Food, Drugs, and Cosmetics Act that were serving as a well-known public statute. The Court also stated that, due to the FDA statute, the main goal was to decrease the level of extreme social harm within the country. That is why the Defendant should be responsible for the impairment caused by his corporation.
The judges also released the information stating that the trial court's instructions could have also left the jury with ambiguous feelings. They suggested that the respondent as the resident might be held guilty due to the absence of illegal activity on his part in the past. The proof of this fact was very much needed for the whole process.
Media for United States v. Park
Audio Transcription for Opinion Announcement - June 09, 1975 in United States v. Park
Warren E. Burger:
I have the judgment and opinion to announce in 74-215, United States against Park.
For reasons stated in an opinion filed with the clerk today, the judgment of the United States Court of Appeals for the Fourth Circuit is reversed.
I have filed a dissenting opinion in this case in which Mr. Justice Marshall and Mr. Justice Powell have joined.
This case involves the criminal conviction of the respondent, John R. Park for violating the Federal Food, Drug, and Cosmetics Act.
The Court of Appeals reversed the judgment of conviction finding that as instructed by the trial judge, the members of the jury were given no objective standards by which to determine whether Park was guilty or innocent and indeed that the jury were allowed to convict Park even if they found no wrongdoing on his part of any kind.
Today the Court reverses the Court of Appeals and reinstates Park's conviction.
Mr. Justice Marshall and Mr. Justice Powell and I, agree with the Court of Appeals that this criminal conviction was totally invalid.
The instructions given by the trial judge in this case were a virtual nullity, a mere authorization to convict if the jury thought it appropriate to do so.
Instructions of -- like that regardless of the blame worthiness of the defendant's conduct, regardless of the social value of the Food, Drug, and Cosmetic Act, and regardless of the importance of convicting those who violate that Act have no place in our jurisprudence.
A fundamental principle of our law is that a jury is to decide the facts and apply to them the law as explained by the trial judge.
Were it otherwise trial by a jury would be no more rational and no more responsive to the accumulated wisdom of the law than trial by ordeal.
It is the function of jury instructions in short to establish in any trial the objective standards that a jury is to apply as it performs its own function of finding the facts.
We deal here with a criminal conviction, not a civil forfeiture.
It is true that the crime was but a misdemeanor and the penalty in this case light.
But under the statute, even a first conviction can result in imprisonment for a year, and a subsequent offense is a felony carrying a punishment of up to three years in prison.
So the standardless conviction approved today can serve in another case tomorrow to support a felony conviction and a substantial prison sentence however highly the Court may regard the social objectives of the Food, Drug, and Cosmetics Act, that regard cannot serve to justify a criminal conviction so wholly alien to fundamental principles of our law.
Before a person can be convicted of a criminal violation of this Act, a jury must find, and must be clearly instructed that it must find, evidence beyond a reasonable doubt that he engaged in wrongful conduct amounting at least to common-law negligence.
There were no such instructions, and clearly, therefore, no such finding in this case.
For the reasons set out in more detail in a written opinion filed with the clerk today, Mr. Justice Marshall, Mr. Justice Powell, and I, respectfully dissent from the opinion and judgment of the Court.
Warren E. Burger:
Thank you Mr. Justice Stewart.