United States v. Crimmins 123 F.2d 271 (1941) was a case before the Second Circuit Court of Appeals

United States Court of Appeals for the Second Circuit

The United States Court of Appeals for the Second Circuit is one of the thirteen United States Courts of Appeals...

 about conspiracy to commit mail fraud. Judge Learned Hand

Learned Hand

Billings Learned Hand was a United States judge and judicial philosopher. He served on the United States District Court for the Southern District of New York and later the United States Court of Appeals for the Second Circuit...

 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

Supreme Court of the United States

The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

 rejected Hand's analogy in United States v. Feola

United States v. Feola

United States v. Feola, 420 U.S. 671 is a United States Supreme Court case in which the court held that conspiracy to assault a federal officer, like the substantive crime of assaulting a federal officer, doesn't require knowledge that the victims were federal officers.The case involved a drug...

(1975), holding that conspiracy to assault a federal agent required no greater mens rea than assault would.

Source

• Stephen A. Saltzburg, et al. Criminal Law-Cases and Materials (2008, Third Ed.) Newark, NJ: LexisNexis. pp 752–53.