United States v. Youts
229 F.3d 1312 (10th Cir. 2000) (2000)
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Rule of Law:
To secure a conviction under the federal train wreck statute, 18 U.S.C. § 1992, the prosecution does not need to prove the defendant had the specific intent to derail or wreck a train. The statute's 'willfully' requirement is satisfied by a showing of knowledge, meaning the defendant was aware that a wreck was a practically certain result of their conduct.
Facts:
- In the early morning of January 10, 1994, Abner Youts and Richard Nesbitt entered the Union Pacific Railyard in Wichita, Kansas.
- The pair boarded two connected, idling locomotives and, after experimenting with the controls, learned how to operate them.
- Youts decided to drive the train to his house.
- Upon arriving near his home, Youts let Nesbitt off the train.
- Youts then put the train into reverse at full throttle and disembarked, sending the driverless locomotives back through town.
- The train, traveling at fifty-six miles per hour, derailed on a downtown curve where the normal speed limit is ten miles per hour.
- The derailment caused approximately $234,145 in damage to Union Pacific and the City of Wichita, though no one was injured.
Procedural Posture:
- Abner Youts was indicted in federal district court on one count of violating 18 U.S.C. § 1992.
- The case was tried before a jury.
- The jury found Youts guilty.
- The district court sentenced Youts to 46 months in prison and ordered him to pay $234,145 in restitution.
- Youts (appellant) appealed his conviction to the U.S. Court of Appeals for the Tenth Circuit, arguing insufficiency of the evidence as to his intent, improper admission of evidence, and mishandling of alleged juror misconduct.
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Issue:
Does the term 'willfully' in the federal train wreck statute, 18 U.S.C. § 1992, require the prosecution to prove that a defendant had the specific intent to wreck a train?
Opinions:
Majority - Seymour, Chief Judge.
No. The term 'willfully' in 18 U.S.C. § 1992 does not require specific intent to wreck a train; it is satisfied by showing the defendant acted knowingly. The court reasoned that while 'willful' can be an ambiguous term, its meaning here is best understood by reference to the Model Penal Code, which equates willfulness with knowledge. A person acts 'knowingly' when they are aware that a result is 'practically certain' to occur from their conduct. The legislative history of § 1992 supports this interpretation, as Congress specifically removed the word 'maliciously' to avoid placing 'too great a burden on the prosecution,' thereby rejecting a heightened culpability standard akin to specific intent. The court concluded that sending a driverless train at full throttle down curving tracks makes a derailment the 'natural, probable, and practically certain consequence,' and therefore Youts's actions satisfied the statute's knowledge requirement.
Analysis:
This decision clarifies the mens rea (mental state) required for the federal crime of wrecking a train, significantly lowering the prosecution's burden of proof. By defining 'willfully' as 'knowingly' rather than 'purposely' (specific intent), the court aligns the statute with modern criminal law principles articulated in the Model Penal Code. This precedent makes it easier to convict defendants for reckless acts whose outcomes are obvious and predictable, even if the defendant did not explicitly desire that outcome. The ruling reinforces the legal principle that individuals are responsible for the natural and probable consequences of their actions.
