In a recent ruling, the Supreme Court vacated the convictions of two physicians for violating the Controlled Substances Act (CSA), essentially holding that the mens rea requirement must be met for an individual to be convicted of a crime. This decision will likely have a large impact on Missouri law going forward, as well as criminal intent cases in general. The purpose of this blog post is to explain the significance of how the U.S. supreme court modified the meaning of criminal intent.
The Supreme Court’s Recent Mens Rea Ruling
On June 27, 2022, the Supreme Court ruled in Ruan v. United States, vacating the convictions of Dr. Xiulu Ruan and Dr. Shakeel Kahn, who had been convicted of violating 21 U.S.C. §841(a) of the Controlled Substances Act (CSA), which prohibits the “knowing or intentional” distribution, manufacture, or dispensing of controlled substances.
Following jury trials, Dr. Ruan and Dr. Kahn, both of whom specialized in pain management, were convicted of prescribing medication outside the standard of care. Both doctors denied any wrongdoing and testified that they had prescribed the medication for a legitimate medical purpose.
The Court’s opinion, authored by Justice Stephen Breyer, held that in order to be convicted of a crime under the CSA, the government must prove that the defendant knew their actions were illegal. This is a major change from prior case law, which held that only a showing of recklessness was required.
The ruling in Ruan v. United States has far-reaching implications, as it will now likely be much more difficult for the government to secure convictions in cases involving health fraud. The opinion also signals a shift in the Court’s thinking on mens rea requirements, which could have an influence on other areas of criminal law.
The Impact on Missouri Law
The Supreme Court’s ruling will have a large impact on Missouri law, particularly as it relates to criminal intent in health fraud cases. Mens Rea specifically refers to the level of intent that a person must have to be found guilty of a crime. If prosecutors attempt to charge a physician or pharmacist with charges related to drug trafficking and/or delivery, the defendant can rebut the state prosecutor’s case by indicating their actions were taken in a manner that was “authorized.” Once the defendant establishes that they acted in an authorized manner, the state prosecutor is then required to prove, beyond a reasonable doubt, that the physician or pharmacist’s actions were unauthorized.
It is not clear what impact, if any, this case will have beyond health fraud cases. In drug possession cases that do not involve health fraud, the prosecution must prove that the defendant possessed drugs, “knowing of its presence and nature.” Broken down a little further, a prosecuting attorney must prove both that the defendant knew that they possessed a substance and also that the defendant knew the substance was drugs. This decision may be used in future drug possession cases where the defendant has an expired prescription for medication to allow for a defense to challenge that they were not knowingly in possession of an unauthorized controlled substance.
The Mens Rea requirement and its impact on Missouri law are sure to be a controversial topic in the coming months. Stay tuned for more updates as this story develops.
Contact the Law Office of Chris Miller for Questions About Criminal Cases
If you have been charged with a crime, it is important to contact an experienced criminal defense attorney as soon as possible. The Law Office of Chris Miller has represented clients in a variety of criminal cases in Columbia, Missouri, and can help you understand the charges against you and build a strong defense. Contact us today for a free consultation.