Staples v. United States

• Mr. Staples = defendant = owner of an AR-15 (semi-automatic rifle) in Colorado
• The AR-15 became automatic (a machine gun) after alterations by someone
• United States = criminal prosecutors = plaintiff
• Staples is arrested for not having registered his weapon as a machine gun

Staples is indicted by a federal grand jury with illegal possession of an un-registered machine gun.

The jury convicted Staples beyond a reasonable doubt with criminal felony.

Must a defendant have known the firearm qualified as an automatic weapon in order to be convicted of illegal possession of an un-registered machine gun?

Staples argued that he hadn't modified the firearm to turn it into a machine gun.

Additionally, Staples claimed that he didn't know that his firearm could be turned into a machine gun with the flip of a switch.

Yes. The prosecution must prove that the defendant knew that the weapon was capable of firing automatically.

Reversed

Clarence Thomas: The mens rea (guilty mind) is presumed to be a requirement in all federal penal statutes even when not mentioned explicitly.

According to the National Firearms Act (NFA), 26 U.S.C. § 5861(d), it is illegal to receive or possess a firearm that is not registered in the National Firearms Registration and Transfer Record 1. This section of the NFA applies to National Firearms Act firearms which include machine guns, short-barreled rifles, short-barreled shotguns, silencers, destructive devices, and any other weapons 2. Violation of this section is a felony and can result in a maximum penalty of 5 years imprisonment and/or a fine of $250,000

This was a 5 to 4 decision. The dissenting justices asserted that most civilian automatic weapons in the United States were the result of conversions from semi-automatic firearms. Therefore, Staples was on notice of this possibility.