## Facts

- Sillasse Bryan was prosecuted in federal district court for dealing in firearms without a federal license, in violation of 18 U.S.C. § 922(a)(1)(A), with penalties under 18 U.S.C. § 924(a)(1)(D) for anyone who “willfully” violates specified provisions including § 922(a)(1)(A).
- The government proved Bryan was engaged in the business of dealing in firearms and did not have a federal firearms license.
- The government also introduced evidence that Bryan knew his conduct was unlawful (including efforts to conceal his activities and use intermediaries).
- There was no evidence Bryan knew of the specific federal licensing requirement applicable to firearms dealers.
- Bryan requested a jury instruction requiring the government to prove he knew of the federal licensing requirement; the trial court refused.
- The trial court instructed that “willfully” meant acting with a “bad purpose to disobey or disregard the law,” and that the defendant need not know the specific law being violated.
- The jury convicted Bryan; the Second Circuit affirmed; the Supreme Court granted certiorari.

## Issues

1. Whether “willfully” in 18 U.S.C. § 924(a)(1)(D) requires proof that the defendant knew his conduct was unlawful and also knew of the specific federal licensing requirement.
2. Whether it is sufficient, for a “willful” violation of § 922(a)(1)(A), to prove only that the defendant acted with knowledge that his conduct was unlawful.

## Decision

- The Supreme Court affirmed, holding that “willfully” in § 924(a)(1)(D) requires proof only that the defendant knew his conduct was unlawful.
- The Court rejected the argument that the government must prove the defendant knew of the specific federal licensing requirement.
- The Court held the trial court’s “bad purpose” instruction, stating the defendant need not know the particular law violated, was consistent with the statute.
- The Court distinguished tax and currency-structuring precedents that required knowledge of specific legal duties, concluding those contexts were exceptional.
- Justice Scalia, joined by the Chief Justice and Justice Ginsburg, dissented, arguing ambiguity should be resolved for the defendant under the rule of lenity.

## Legal Principles

- In criminal statutes, “willfully” generally requires proof the defendant acted with knowledge that his conduct was unlawful (a “bad purpose”), not proof the defendant knew the specific statute or regulatory duty violated.
- “Knowingly” typically addresses awareness of the facts constituting the offense, while “willfully” can require a finding that the defendant understood his conduct was illegal in a general sense.
- Context-specific readings of “willfully” that require knowledge of the precise legal duty (such as in certain tax and structuring offenses) are limited exceptions driven by statutory context and risk of punishing innocent conduct.
- Interpreting “willfully” to require knowledge of illegality, but not detailed statutory knowledge, is consistent with the general rule that ignorance of the law is no excuse.

## Conclusion

The Court held that a “willful” violation of the federal firearms dealer licensing prohibition is established by proof that the defendant knew his conduct was unlawful; the government need not prove the defendant knew the specific federal licensing requirement.


Bryan v. United States, 524 U.S. 184 (1998)