United States v. Hitachi America, Ltd.
United States Court of Appeals for the Federal Circuit
172 F.3d 1319 (1999)
- Written by Gonzalo Rodriguez, JD
Facts
Hitachi, Ltd. (Hitachi Japan) (defendant) manufactured subway cars in Japan that were then imported into the United States by Hitachi America, Ltd. At the time of importation, Hitachi America declared that the value of the subway cars was $40 million, although it had paid $68 million to Hitachi Japan. The United States Customs Service (customs) (plaintiff) initiated enforcement actions under 19 U.S.C. § 1952(a) against Hitachi America for underreporting and against Hitachi Japan for negligently aiding and abetting Hitachi America’s conduct, arguing that Hitachi Japan should have known of Hitachi America’s unlawful conduct. Hitachi Japan argued that it could not be held liable for negligently aiding or abetting Hitachi America because, as a matter of law, aiding or abetting required intent. Interpreting the Restatement of Torts, which stated that “one is subject to liability if he . . . knows that the other’s conduct constitutes a breach of duty,” the court held that a party could unintentionally aid or abet a negligent violation of custom laws, and thus that Hitachi Japan was liable. Hitachi Japan appealed.
Rule of Law
Issue
Holding and Reasoning (Michel, J.)
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