Staples v. United States

511 U.S. 600 (1994)

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Nature of the Case

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Facts

ATF agents served a search warrant on D’s home. They discovered an AR-15. The metal stop on D's rifle had been filed away, and the rifle had been assembled with an M-16 selector switch and several other M-16 internal parts, including a hammer, disconnector, and trigger. D was charged with possession of an unregistered firearm punishable by 10 years in prison. The rifle found in D's possession was capable of firing automatically more than one shot with single pull of the trigger. This had been accomplished by removing a metal piece that had originally precluded automatic firing. D testified that the rifle had never been fired automatically in his possession and that he was not even aware that it had that ability. D sought a jury instruction that the government must show that D knew that the gun would fire automatically. This was refused, and D was convicted and appealed. The Court of Appeals confirmed and the Supreme Court granted certiorari. D contends that to convict him under the Act, the Government should have been required to prove beyond a reasonable doubt that he knew the weapon he possessed had the characteristics that brought it within the statutory definition of a machinegun.