Have we abandoned the principle of Innocent until prove Guilty?

[Not Ruth]

34. This guy beat the gun laws by claiming to be stupid

http://www2.ca3.uscourts.gov/opinarch/95a1149p.txt


In January 1993, Pennsylvania authorities charged
Hayden with receiving stolen property and with the
unauthorized use of an automobile. Hayden received a copy
of the criminal information, and he signed a form
acknowledging receipt that was captioned, in capital
letters, "RECEIPT OF COPY OF INFORMATION." Below the caption
were the words, "I hereby certify that I have received a
copy of the information filed by the District Attorney in
the above-captioned action," and the accompanying document
states that "[t]he District Attorney of Allegheny County by
this information charges" Hayden with receiving stolen
property and unauthorized use of automobiles and other
vehicles.
A month after receiving the information, Hayden
went to a firearms dealer and inquired about purchasing a
pistol. The dealer told Hayden that there was a waiting
period and that the Allegheny County Sheriff's Office and
Pennsylvania State Police would be notified. Hayden then
asked about purchasing a rifle. In response, the dealer told
him he must give proper identification, be eighteen years of
age, and fill out a Bureau of Alcohol, Tobacco, and Firearms
Form 4473, which was subject to ATF inspection.
Hayden purchased an AK-47, a semiautomatic rifle
with a magazine capacity of one hundred rounds. He also
filled out a Form 4473 which defined the meaning of the
words "indictment" and "information" and inquired:
Are you under indictment or information*
in any court for a crime punishable by
imprisonment for a term exceeding one
year?
* A formal accusation of a crime made by
a prosecuting attorney, as distinguished
from an indictment presented by a grand
jury.

Hayden answered "no" to this question, even though Form 4473

twice warned that it was unlawful to answer any of the

questions falsely, stating that "[a]n untruthful answer may
subject you to criminal prosecution." Just above Hayden's
signature, the form provided the following certification:
I understand that a person who answers
"Yes" to any of the above questions is
prohibited from purchasing and/or
possessing a firearm, except as
otherwise provided by Federal Law. I
also understand that the making of any
false oral or written statement or the
exhibiting of any false or
misrepresented identification with
respect to this transaction is a crime
punishable as a felony.
The ATF ran a criminal history check on Hayden and
found the information pending in Allegheny County. Hayden
was indicted and charged with one count of violating 18
U.S.C.
§ 922(n), receiving a firearm while under an indictment or
information. At a non-jury trial, Hayden attempted to prove
that his low intelligence and reading ability prevented him
from understanding the document sent to him was an
"information" and that, in purchasing a gun, he did not know
he was violating the law. The district court prevented such
testimony from Hayden and his experts, ruling that the
government need not prove he knew he was violating the law.
Hayden was convicted and sentenced to eight months in
prison, three years of supervised release, and a $50 special
assessment.
II.
Hayden was charged under 18 U.S.C. § 922(n), which
provides as follows:
It shall be unlawful for any person
who is under indictment for a crime
punishable by imprisonment for a term
exceeding one year to ship or transport
in interstate or foreign commerce any
firearm or ammunition or receive any
firearm or ammunition which has been
shipped or transported in interstate or
foreign commerce.
Section 922(n) has a corresponding penalty provision, found
in 18 U.S.C. § 924(a)(1)(D), which provides:
(a)(1) Except as otherwise provided in
this subsection, subsection (b), (c), or
(f) of this section, or in the section
929, whoever --

(D) willfully violates any other
provision of this chapter, shall be
fined not more than $5,000, imprisoned
not more than five years, or both.
(emphasis added).
The district court had jurisdiction under 18
U.S.C. §3231 (1988). We have jurisdiction under 28 U.S.C. §
1291 (1988). Because § 924(a)(1)(D)'s willfulness language
involves statutory interpretation, our standard of review is
plenary. United States v. Meraz, 998 F.2d 182, 183 (3d Cir.
1993). We review the trial court's evidentiary rulings for
an abuse of discretion. United States v. Sampson, 980 F.2d
883, 889 (3d Cir. 1992).