United States v. Strong, No. 12-1842 (1st Cir. 2013)
Annotate this CaseDefendant was convicted of willfully damaging federal property, creating a hazard on federal property, and creating a nuisance on federal property after he badly soiled a federal courtroom. Defendant appealed, arguing that because the regulations he was charged with violating were posted inside rather than outside the courthouse entrance, his conviction must be reversed pursuant to 40 U.S.C. 1315(c)(1) and a General Services Administration (GSA) regulation. The First Circuit Court of Appeals affirmed, holding (1) the regulations were posted in compliance with the statute, which requires posting of the regulations Defendant violated in a conspicuous place on the property; (2) while the GSA regulation specifies that the notice about the rules governing the building should be posted at the public entrance, the regulation does not provide that imperfect compliance with the exterior posting requirement nullifies a conviction for violating the prohibition; and (3) sufficient evidence established that Defendant had the mental state required for his conviction.
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