Ruan v. United States

The crime of prescribing controlled substances outside the usual course of professional practice, in violation of 21 U.S.C. § 841, requires that the defendant “knowingly or intentionally” acted in an unauthorized manner. Justice Stephen Breyer authored the majority opinion of the Court. In general, criminal law seeks to punish conscious wrongdoing. Thus, when a criminal statute is silent as to the mental state required, courts infer a requirement of knowledge or intent. When it is not silent, the general mental state provision applies to each term of the provision. Thus, the “knowingly or intentionally” requirement of 21 U.S.C. § 841 applies to the phrase “except as authorized.” As such, once the defendant proves their conduct was “authorized,” the prosecution must prove beyond a reasonable doubt that the defendant acted in an unauthorized manner. Justice Samuel Alito authored an opinion concurring in the judgment, in which Justices Clarence Thomas and Amy Coney Barrett joined. Justice Alito looked to the Harrison Act, which preceded the Controlled Substances Act (CSA). Regarding the Harrison Act, the Court held that a registered physician acts “in the course of his professional practice” when the physician writes prescriptions “in good faith.” Justice Alito would thus hold that this rule applies under the CSA and vacate the judgments below and remand for further proceedings.