United States v. Park Case Brief

Why is the case important?

The Defendants, a food corporation and its CEO (Defendants), were convicted of keeping food sold in interstate commerce in a rodent-infested warehouse, in violation of federal regulations.

Facts of the case

Question

Is CEO of corporation criminally responsible for unlawful actions of the corporation?

Answer

Yes. Reversed. The Government established a prima facie case against the defendant CEO with evidence that the defendant was put on notice of a violation of law committed by the corporation and that he both failed to prevent the violation of law in the first place and subsequently failed to promptly correct the unlawful activity. The defendant could only have avoided liability by demonstrating that he was powerless to prevent or correct the violation of law, but he failed to do so.

Conclusion

The court held that the jury’s attention was properly focused on the corporate officer’s authority over the conditions that formed the basis of the violations. The main issue for determination was the corporate officer’s accountability. The instructions to the jury were not misleading and contained an adequate statement of the law. There was no basis to conclude that the failure of the court to give specific instructions sua sponte was plain error or a defect affecting the corporate officer’s substantial rights under Fed. R. Crim. P. 52(b).

  • Case Brief: 1975
  • Petitioner: United States
  • Respondent: John R. Park
  • Decided by: Burger Court

Citation: 421 US 658 (1975)
Argued: Mar 18 – 19, 1975
Decided: Jun 9, 1975