Xiulu Ruan v. United States

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Criminal Law
  • Date Filed: June 27, 2022
  • Case #: 20–1410
  • Judge(s)/Court Below: BREYER, J. delivered the opinion of the Court, in which ROBERTS, C. J., and SOTOMAYOR, KAGAN, GORSUCH, and KAVANAUGH, JJ., joined. ALITO, J., filed an opinion concurring in the judgment, in which THOMAS, J., joined, and in which BARRETT, J., joined as to Parts I–A, I–B, and II.
  • Full Text Opinion

21 U. S. C. § 841’s “knowingly or intentionally” mens rea applies to the statute’s “except as authorized” clause.

Petitioners are the consolidated cases of two doctors convicted by jury trials for violating 21 U. S. C. § 841, “knowingly or intentionally . . . distribut[ing], or dispens[ing]. . . a controlled substance” when not “authorized”. At trial Petitioners each argued the drugs were distributed by effective prescriptions, a “legitimate medical purpose,” and appealed the Court’s mens rea jury instructions.  See 21 CFR § 1306.04(a) (2021). The appellate courts affirmed. On appeal, the Supreme Court held that the statute’s mens rea requirement, “knowing or intentionally,” applies to the “authorized” exception. Criminal laws are presumed to punish the culpable mental state, which reduces the risk of “overdeterrence,” and harming potentially socially beneficial behavior. A strong scienter requirement like “knowing or intentionally” applied to “authorization” has support of analogous criminal statutes, in order to not criminalize innocent conduct. United States v. X-Citement Video, Inc., 513 U. S. 64, 73 (1994). Subjective intent should not be read into the mens rea requirement for the authorization exception; the statute does not use subjective language, and inferring a reasonable person standard is not typical in criminal contexts. VACATED AND REMANDED.

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