United States v. St. Onge

District Court, D. Montana
676 F.Supp. 1044 (1988)

ELI5:

Rule of Law:

To secure a criminal conviction under the Endangered Species Act, the government must prove the defendant knowingly committed the act of taking an animal, but it does not need to prove the defendant knew the specific identity of the animal was that of a protected species.

Facts:

A defendant was hunting in one of the 48 coterminous states.
The defendant shot and killed an animal with a firearm.
The animal killed was a grizzly bear, a threatened species protected by the Endangered Species Act.
The defendant asserted that at the time of the shooting, he believed the animal was an elk, not a grizzly bear.
The defendant did not have permission from the U.S. Department of the Interior to take a grizzly bear.

Procedural Posture:

The United States brought a criminal charge against the defendant in the U.S. District Court for violating the Endangered Species Act.
Prior to trial, the United States filed a motion in limine seeking to exclude evidence that the defendant believed he was shooting an elk rather than a grizzly bear.

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Issue:

Does the 'knowingly' requirement in the Endangered Species Act, 16 U.S.C. § 1540(b)(1), require the government to prove that a defendant knew the specific identity of the animal he was taking was a protected species, or only that he knowingly took an animal that was, in fact, a protected species?

Opinions:

Majority - Lovell

No. The 'knowingly' requirement in the Endangered Species Act applies to the act of taking an animal, not to the defendant's knowledge of the animal's specific identity as a protected species. The court reasoned that the Endangered Species Act is a regulatory statute designed for the broad protection of threatened species, and its purpose would be 'eviscerated' if the government had to prove specific intent—that is, that the defendant recognized the specific protected animal. Citing legislative history, the court determined Congress intended to make criminal violations of the Act a general intent crime, focusing on whether the defendant knowingly engaged in the prohibited conduct (the taking of an animal). The court distinguished this from a mistake or accident, such as an unintentional firearm discharge, which would negate the 'knowingly' element. Therefore, the defendant’s mistaken belief about the species is not a valid defense.

Analysis:

This decision clarifies that the Endangered Species Act imposes a general intent standard for criminal liability, significantly lowering the prosecution's burden of proof. By treating this as a public welfare offense, the court places the risk of species misidentification squarely on the hunter, rather than on the protected species. This strengthens the Act’s protective power and aligns it with other regulatory statutes where the harm to the public good is the primary concern, regardless of the defendant's specific knowledge of all facts that make their conduct illegal.

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