United States v. White Fuel Corporation
United States Court of Appeals for the First Circuit
498 F.2d 619 (1974)
- Written by Sara Adams, JD
Facts
White Fuel Corporation (defendant) operated an oil-tank farm adjacent to a cove of the Boston Harbor. In May 1972, the Coast Guard found oil in the cove’s water. White Fuel admitted ownership of the oil. White Fuel discovered the oil had seeped into the cove from a large quantity of oil that had accumulated under White Fuel’s property. By September 1972, White Fuel had stopped the leak. White Fuel was charged with violating § 13 of the Rivers and Harbors Act of 1899, 33 U.S.C. § 407 (the Refuse Act). After a nonjury trial, the district court convicted White Fuel of violating the Refuse Act. The district court denied White Fuel’s motion for judgment of acquittal and request to present evidence showing White Fuel did not know of the oil spill and acted diligently in remedying the issue. White Fuel appealed, arguing that the government failed to prove scienter or negligence on the part of White Fuel and that White Fuel should have been permitted to introduce evidence that it did not know about the underground oil and acted swiftly to fix the spill once informed.
Rule of Law
Issue
Holding and Reasoning (Campbell, J.)
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