United States v. International Minerals & Chemical Corp.
402 U.S. 558 (1971)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
For public welfare offenses involving inherently dangerous or deleterious materials, a statute penalizing one who 'knowingly violates' a regulation requires proof only that the defendant knew the facts constituting the offense, not that the defendant had knowledge of the specific regulation itself.
Facts:
- International Minerals & Chemical Corp. shipped sulfuric acid in interstate commerce.
- International Minerals & Chemical Corp. also shipped hydrofluosilicic acid in interstate commerce.
- Both sulfuric acid and hydrofluosilicic acid are categorized as hazardous 'Corrosive Liquid' materials under federal regulations.
- The shipping papers for these shipments failed to include the required classification, 'Corrosive Liquid'.
Procedural Posture:
- The United States filed a criminal information against International Minerals & Chemical Corp. in a federal District Court.
- The District Court dismissed the information, holding that it did not charge a 'knowing violation' of the regulation.
- The United States filed a notice of appeal to the Court of Appeals.
- Relying on statute, the United States then moved to certify the case directly to the Supreme Court of the United States.
- The Court of Appeals certified the case, and the Supreme Court noted probable jurisdiction to hear the appeal.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the term 'knowingly violates any such regulation' in 18 U.S.C. § 834(f) require the government to prove the defendant had knowledge of the specific regulation being violated, in addition to knowledge of the facts of the shipment?
Opinions:
Majority - Mr. Justice Douglas
No. The term 'knowingly violates any such regulation' does not require proof of knowledge of the law itself, only that the defendant had knowledge of the facts constituting the violation. This case involves a public welfare offense, concerning inherently dangerous materials, where the long-standing principle that 'ignorance of the law is no excuse' applies. The word 'knowingly' provides the necessary mens rea by requiring that the defendant knew they were shipping a dangerous substance, like acid, rather than an innocent one, like distilled water. Where dangerous products are involved, the probability of regulation is so great that anyone dealing with them must be presumed to be aware of the regulations.
Dissenting - Mr. Justice Stewart
Yes. A person cannot 'knowingly violate a regulation' unless they know of the terms of the regulation. The plain language of the statute requires knowledge of the regulation itself. This interpretation is supported by prior federal court decisions and by explicit legislative history; in 1960, Congress considered and rejected an amendment that would have removed this requirement, specifically choosing to retain the word 'knowingly' and the judicial interpretation that accompanied it. The majority's decision effectively deletes 'knowingly' from the statute and unfairly criminalizes the conduct of casual shippers who are unaware of complex shipping regulations.
Analysis:
This decision reinforces the public welfare offense doctrine, which lowers the mens rea requirement for crimes related to public health and safety. By holding that 'knowingly' applies only to the facts of the conduct (shipping acid) and not the law itself (the regulation), the Court makes it significantly easier for the government to secure convictions against those who handle hazardous materials. This precedent solidifies the legal presumption that individuals and corporations engaged in inherently dangerous activities have a duty to be aware of the governing regulations, thereby strengthening the enforcement power of administrative agencies in safety-critical sectors.
Unlock the full brief for United States v. International Minerals & Chemical Corp.