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United States v. Plaza Health Laboratories, Inc.

United States Court of Appeals for the Second Circuit
3 F.3d 643 (2d. Cir. 1992)


Geronimo Villegas (defendant), co-owner and vice president of Plaza Health Laboratories, Inc. (Plaza Health) (defendant), a blood testing laboratory in Brooklyn, New York, dumped approximately 70 vials of human blood in the Hudson River on at least two separate occasions. Villegas was charged with two counts of knowingly discharging pollutants from a “point source” without a permit and two counts of knowingly discharging pollutants into navigable water in violation of the Clean Water Act (CWA). 33 U.S.C. §§ 1311 and 1319(c)(2). A jury convicted Villegas on all four counts. After the verdict, the court entered a judgment of acquittal on two of the four counts, namely those charging Villegas with knowingly discharging pollutants into the river in violation of the CWA. Villegas appealed. The government cross-appealed, claiming the court erred by entering the judgment of acquittal.

Rule of Law


Holding and Reasoning (Pratt, J.)

Dissent (Oakes, J.)

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