Date argued 1941 | ||
United States v. Crimmins 123 F.2d 271 (1941) was a case before the Second Circuit Court of Appeals about conspiracy to commit mail fraud. John D. Crimmins purchased bonds in Syracuse that he knew to be stolen but he did not know they were stolen from New York City and mailed to upstate New York. Judge Learned Hand wrote the court's opinion. Hand reasoned that conspiracy to commit mail fraud required a higher mens rea—purpose instead of reasonable foreseeability—than the substantive crime of mail fraud. To bolster his opinion, Hand made a famous analogy. He argued that while one may inadvertently run a red light, conspiracy to run a red light is an agreement that requires the conspirators know that the light is red. Likewise, conspiracy to commit mail fraud requires prior knowledge that the conspirators will use the mails.
The United States Supreme Court rejected Hand's analogy in United States v. Feola (1975), holding that conspiracy to assault a federal agent required no greater mens rea than assault would.