Criminal Law

United States v. Jackson — Study Notes

560 F.2d 112 (2d Cir. 1977)

Study notes for United States v. Jackson: professor notes, cold call prep, exam angles, and memory aids.

Impossibility is not a valid defense to an attempt charge if a defendant acts on a belief that they are committing a crime, regardless of the crime's factual completion.
Professor Notes

United States v. Jackson explores crucial principles regarding criminal attempts, particularly in the context of receiving stolen goods. The case exemplifies that even if the intended goods were not in fact stolen, the defendants' belief and actions toward obtaining such goods can ground liability for an attempt to commit a crime. The court emphasizes the significance of intent and the steps taken towards the commission of the crime, reflecting a broader interpretation of attempt liability that places less emphasis on the factual completion of the underlying crime.

This case also provides a platform for discussing the subjective vs. objective standard when evaluating attempt cases. Students should understand the implications of the decision regarding mens rea and whether a subjective belief concerning the nature of goods can suffice for an attempt charge, emphasizing that the mental state of the defendants and their proactive steps are paramount even in cases of factual impossibility.

Cold Call Prep
  1. 1Explain why impossibility is not a defense in this case.
  2. 2What did the court identify as substantial steps toward committing the crime?
  3. 3Discuss the mens rea necessary for attempt in this case.
  4. 4How would you distinguish this case from Strayer v. United States?
  5. 5What implications does this case have for future attempts related to receiving stolen property?
  6. 6Explain the court's rationale in affirming the convictions despite the non-existence of the theft.
Mnemonic Device

IS - Intent and Steps = Impossibility not a Defense

Distinguish From
CaseDistinction
People v. Thousand IslandsIn Thousand Islands, defendants were not found guilty of attempt because their actions lacked any clear intent to commit the underlying crime.
State v. LeeIn Lee, the impossibility defense was applicable because the intended crime could not have been committed under any circumstances, unlike in Jackson where the action took place under a mistaken belief.
Policy Arguments

For the Rule

Allowing attempt liability in cases of perceived crime promotes societal norms against receiving stolen goods and discourages criminal conspiracies even where factual impossibility exists.

Against the Rule

Imposing liability under a mistaken belief about the nature of goods can lead to unjust punishment of individuals who may not have intended to commit a crime at all if the belief was genuine.

Class Discussion Points
  • Discuss the implications of this ruling on the doctrine of impossibility in criminal law.
  • How does this case reflect the balance between intention and actions in the assessment of criminal liability?
  • Consider the potential for abuse in policing practices following this case's precedent.
Exam Angle

This case is likely to appear in exams focusing on the elements of attempt liability and the implications of factual versus legal impossibility.

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