United States V. Weitzenhoff - Ninth Circuit's Opinion: The Issue of Intent

Ninth Circuit's Opinion: The Issue of Intent

On appeal, the defendants argued that the judged erred in his/her interpretation of the statute and in the instruction of the jury. They argued that the judge was wrong to instruct the jury that no proof was needed to show they knew their act was unlawful, and that the judge failed to instruct the jury that the Defendants mistakenly thought they were authorized to dump the waste under a permit.

The defendants relied on Liparota v. United States in their defense, case involving the fraudulent use of food stamps. There the U.S. Supreme Court had interpreted the word “knowingly” in the statute as implying actual knowledge of the legal violation. The Ninth Circuit distinguished Liparota on the grounds that it did not pertain to acts that cause public endagerment, and therefore criminal liability needed to be used more sparingly. The Ninth Circuit found more applicable the case United States v. International Minerals & Chem. Corp., in which the Supreme Court had held that when one handles wastes and dangerous materials, knowledge of the regulations is assumed.

The Ninth Circuit affirmed the judgment of the district Court.