specific intent crimes

Ronald Harmelin was convicted in Michigan state court of possessing 672 grams of cocaine. Michigan law imposed a mandatory sentence of life imprisonment without possibility of parole for that quantity of the drug. Harmelin had no prior felony convictions. The Michigan Court of Appeals initially reversed the conviction because evidence supporting it had been obtained in violation of the Michigan Constitution. On petition for rehearing, the Court of Appeals vacated its prior decision and affirmed the sentence. The Michigan Supreme Court denied leave to appeal. The United States Supreme Court granted certiorari. The quantity of cocaine at issue had a potential yield of between 32,500 and 65,000 doses. The sentencing court imposed the mandatory term without considering any individualized circumstances of the offense or the offender. Harmelin challenged the sentence on Eighth Amendment grounds, arguing both that it was grossly disproportionate to the crime and that the mandatory nature of the penalty was unconstitutional.

In December 1948, Morissette went hunting on a large tract of land in Michigan that the Government had used as a practice bombing range for the Air Force. Spent bomb casings from the range had been dumped into heaps and left exposed to the weather for four years or more. Morissette collected three tons of the casings, flattened them at a nearby farm, and sold them for eighty-four dollars. Morissette worked as a fruit stand operator in the summer and as a trucker and scrap iron collector in the winter. He was an honorably discharged veteran of World War II who had a good reputation among his neighbors. He loaded the casings onto his truck and transported them in broad daylight without any effort to conceal what he was doing. When authorities began an investigation, Morissette voluntarily and candidly told them the whole story, explaining that he believed the casings were abandoned and that he had no intention of stealing them. He was indicted for unlawfully, willfully, and knowingly stealing and converting property of the United States valued at eighty-four dollars in violation of 18 U.S.C. § 641. At trial, the District Court refused to permit Morissette to show that he thought the property was abandoned or to argue that he lacked criminal intent. The court instructed the jury that if it believed the government testimony, Morissette was guilty, and the jury convicted him. The court sentenced him to two months in prison or a fine of two hundred dollars. The Court of Appeals affirmed the conviction. The Supreme Court granted certiorari.

In March 1944 petitioner Fisher, the janitor at the library of the Cathedral of Saint Peter and Saint Paul in Washington, D.C., killed librarian Catherine Cooper Reardon inside the library building between eight and nine o'clock on the morning of March 1. Reardon had complained a few days earlier to the verger about Fisher's care of the premises, and the verger had informed Fisher of the complaint. Fisher and Reardon were alone in the library at the time of the homicide. Fisher testified that Reardon spoke insulting words about his work, after which he slapped her impulsively. He ran up a flight of steps toward an exit but turned back, seized a stick of firewood, struck her, and when the stick broke choked her to silence. He then dragged her to a lavatory and left the body to clean up some spots of blood on the floor outside. While Fisher was doing this cleaning up, the victim started hollering again. Fisher then took out his knife and stuck her in the throat. After that he dragged her body down into an adjoining pump pit, where it was found the next morning. Fisher's accounts of the events varied. His original confession made no reference to insulting words from Reardon. His written confession mentioned them, and his trial testimony amplified their effect on him. In the written confession he admitted his main reason for assaulting her was that she had reported him for not cleaning the floor. The Deputy Coroner testified that the knife wound was not deep and only went through the skin. Defense psychiatrists testified that Fisher was a psychopathic personality of a predominantly aggressive type, mentally somewhat below average, with minor stigmata of mental subnormalcy, and that he was unable by reason of a deranged mental condition to resist the impulse to kill. The prosecution introduced competent evidence that Fisher was capable of understanding the nature and quality of his acts. All evidence offered by the defense was received by the trial court. Fisher was tried in the District Court of the United States for the District of Columbia on an indictment charging killing by choking and strangling with deliberate and premeditated malice. The jury returned a verdict of guilty on the first count, and the court imposed a sentence of death. The United States Court of Appeals for the District of Columbia affirmed the judgment and sentence.

In 1951, fourteen leaders of the Communist Party in California were indicted in the United States District Court for the Southern District of California under the Smith Act and 18 U.S.C. § 371. The single-count indictment charged them with conspiring from 1940 until the date of the indictment. They were charged to advocate and teach the duty and necessity of overthrowing the Government of the United States by force and violence. They were also charged to organize as the Communist Party of the United States a society of persons who so advocate and teach. All of this was with the intent of causing the overthrow of the Government by force and violence as speedily as circumstances would permit. The indictment alleged twenty-three overt acts in furtherance of the conspiracy. These included that the defendants would become members and officers of the Party, cause units to be organized in California, write and publish articles, conduct schools for indoctrination, and recruit new members from key industries. After a jury trial, each petitioner was convicted and sentenced to five years' imprisonment and a fine of $10,000. The Court of Appeals affirmed the convictions. The Supreme Court granted certiorari to consider questions including the construction of the term "organize," the adequacy of the trial court's instructions, the sufficiency of the evidence as to particular petitioners, and the applicability of collateral estoppel based on a prior decision. The evidence at trial included testimony about Party classes and episodes in San Francisco and Los Angeles during 1946 and later. It also included an "underground" apparatus where trusted individuals were instructed for tasks to be performed when action might occur. The proof against petitioners Connelly, Kusnitz, Richmond, Spector, and Steinberg showed largely lawful activities, membership or office in the Party, and at best advocacy of abstract doctrine. Testimony tied petitioners Carlson, Dobbs, Fox, Healey, Lambert, Lima, Schneiderman, Stack, and Yates to systematic teaching that might be considered preparation for violent action. Two overt acts proved within the statute of limitations consisted of public Party meetings where speeches extolling the Soviet Union and criticizing United States foreign policy were made. Petitioner Schneiderman had previously prevailed in a denaturalization proceeding, Schneiderman v. United States, 320 U.S. 118, decided in 1943. That proceeding involved determinations about activities in 1927. The trial court refused to give instructions treating those determinations as conclusive in the manner requested by Schneiderman.