McFadden v. United States (2014)
- Docket
- 14-378
- Decided
- 2014-01-01
Summary
Question: To convict someone under the Controlled Substances Analogue Act, does the government need to prove that the defendant knew the substance was an analogue to a controlled substance? Conclusion: Yes. Justice Clarence Thomas delivered the opinion of the 9-0 majority. The Court held that, in order to fulfill the intent element, the defendant may either know that the substance in question is a controlled substance without knowing what the substance is, or may know what the substance is but not know that it is controlled. In either scenario, the defendant is aware of all he needs to know to fulfill the knowledge element. A complete and thorough knowledge of the law surrounding controlled substances is not necessary to fulfill the knowledge requirement, and even in a case where the defendant does not know of the Analogue Act, he may be found guilty because ignorance of the law is no excuse. Chief Justice John G. Roberts, Jr., wrote an opinion concurring in part and concurring in the judgment in which he argued that knowledge of the identity of the substance fell short of satisfying the knowledge element. In this instance, ignorance of the law could be a defense because the individual could lack knowledge of the legal element: the fact that the substance is controlled.