⚖︎
AI-verified law

Law Student Workbench

Multiple AIs, cross-checked — every citation verified against real law.

✓ Every cited case verified against real law
Criminal Law · Mens rea · Case brief

Morissette v. United States

342 U.S. 246 · Supreme Court of the United States · 1952
⚠ That citation didn’t resolve — the brief below is from the model, not a retrieved opinion. Verify before relying.
A study aid, not legal advice. This brief was drafted by AI; what makes it different is that every case it cites is checked against real case law — read the opinion itself before relying on it.
✓ Reviewed by 2 AIs against the opinion — every field checked out.

Facts

Morissette, a scrap metal collector, entered an Air Force bombing range and took spent bomb casings that had long lain scattered there. He believed the casings had been abandoned and sold them for scrap. He was prosecuted under a federal statute making it a crime to knowingly convert government property. At trial, the judge refused to let the jury consider Morissette's claim that he lacked criminal intent, and the jury convicted him.

Accurate?

Issue

When a federal statute criminalizes "knowingly convert[ing]" government property but does not expressly mention intent, must the government still prove a criminal intent or guilty mind?

Accurate?

Rule

Mere silence in a criminal statute on the element of intent does not ordinarily eliminate the traditional requirement of mens rea. For crimes derived from common-law offenses such as larceny or conversion, courts presume Congress intended to require a guilty mind unless it clearly indicates otherwise.

Accurate?

Holding

Yes. The Court held that criminal intent was an essential element of the offense and that the trial court erred by withholding that issue from the jury. Morissette's conviction was reversed.

Accurate?

Reasoning

Justice Jackson explained that theft-related crimes have historically required proof of a culpable mental state, and Congress is presumed to legislate against that common-law background. The phrase "knowingly converts" incorporated the traditional notion that the defendant must intentionally take property he knows is not his to take. The Court distinguished so-called public welfare offenses, where strict liability may be permitted for regulatory crimes, from traditional crimes carrying moral condemnation and substantial penalties. Because Morissette's belief that the property was abandoned bore directly on intent, the jury had to decide that question.

Accurate?

Significance

Morissette is a foundational modern statement of the presumption of mens rea in federal criminal law. It sharply distinguishes traditional common-law crimes from strict-liability public welfare offenses and is regularly cited when courts decide whether to read a mental-state requirement into a statute. Closely related cases include United States v. Balint, 258 U.S. 250 (1922), United States v. Dotterweich, 320 U.S. 277 (1943), Staples v. United States, 511 U.S. 600 (1994), Liparota v. United States, 471 U.S. 419 (1985), and Elonis v. United States, 575 U.S. 723 (2015).

Accurate?
Citations in this brief — every case checked
United States v. Balint, 258 U.S. 250 (1922)
Abstain
United States v. Dotterweich, 320 U.S. 277 (1943)
Abstain
Staples v. United States, 511 U.S. 600 (1994)
Abstain
Liparota v. United States, 471 U.S. 419 (1985)
Abstain
Elonis v. United States, 575 U.S. 723 (2015)
Abstain

Brief any case, with citations you can trust

Enter a case name or citation — get a structured brief where every case it cites is checked against real law.

Try Law Student Workbench →