Labels:book | reckoner | sky OCR: 17 States Scanio, supra, 900 F.2d 485, the leading case contrary to Aversa explain how "willfully" can mean two different things 1r one occurrence The closest any of the cases comes to even discussing this point Scanio itself But all the Second Circuit does acknowledge the differ- ing meanings and state policy reason Congress might wish impose different mental elements far the two crimes 900 F.2d at 484 -85. Nothing T the language of 5322 shows that Congress did fact impose different elements Nor does Scanio add ress the point made Aversa that although Cong ress might want impose different elements for violations different provisions the struchre of the Subchapter shows that it P!P not Curiously the court below spoke of "the distinction between 'willful' as pasn ir section 5324(3) pue as e ...
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