United States v. Hanousek

Edward Hanousek, Jr. (defendant), roadmaster of a railroad running along the Alaska-Yukon border, took over a rock-quarrying project near a petroleum pipeline running alongside the tracks after a contractor had already installed protective ties and ballast material over one section of pipeline. Under Hanousek's oversight, no comparable protection was extended to other sections; a contractor's employee later struck the unprotected pipeline with a backhoe bucket while clearing rocks, rupturing it and discharging thousands of gallons of oil into a nearby river. The government charged Hanousek under the Clean Water Act with negligently discharging oil into navigable waters, and the jury convicted him after being instructed on an ordinary negligence standard; Hanousek appealed, arguing the statute should require proof of gross negligence and that its application to ordinary negligence violated due process.