General Intent Sufficient Under 18 U.S.C. § 111: United States v. Parrot

Introduction

United States v. Parrot, decided by the First Circuit on March 21, 2025, addresses the scope of the general‐intent requirement under 18 U.S.C. § 111, which criminalizes the forcible assault of a federal officer. The appellant, Alan Howell Parrot, admitted pushing an FBI agent with his foot while she attempted to prevent him from shutting a sliding glass door, injuring her in the process. Parrot conceded he knew the victim was a federal officer but argued on appeal that his lack of knowledge of the officers’ valid search warrant—and the trial court’s refusal to give a jury instruction on that point—undermined the verdict. He also challenged the court’s self‐defense instruction. The First Circuit rejected both arguments and affirmed his conviction.

Summary of the Judgment

The First Circuit affirmed Parrot’s conviction under 18 U.S.C. § 111, holding:

Section 111 is a general‐intent statute requiring only that the defendant intended the assaultive act, not that he specifically intended to assault an officer performing official duties or knew all legal details (e.g., the existence of a search warrant).
Parrot’s proposed jury instruction—that his ignorance of the search warrant could negate intent—was “not substantively correct” and would transform the statute into one requiring specific intent.
His challenge to the self‐defense instruction was forfeited in the district court, and no plain error was shown.

Analysis

Precedents Cited

United States v. Feola, 420 U.S. 671 (1975)—Held that § 111 requires only a general intent to commit the assault, not a specific intent to assault a federal officer. Parrot’s case turned on this principle: knowledge of officer status suffices.
Carter v. United States, 530 U.S. 255 (2000)—Distinguished general intent from specific intent crimes. The court reiterated that general‐intent statutes require proof of intent to commit the proscribed act, not intent to achieve a further specific result.
United States v. Denson, 689 F.3d 21 (1st Cir. 2012)—Established that a requested jury instruction must be (a) substantively correct, (b) not covered by other instructions, and (c) essential to the defense to warrant reversal for refusal.
Pierre v. Attorney General, 528 F.3d 180 (3d Cir. 2008)—Clarified the distinction between general and specific intent in criminal law, supporting the conclusion that § 111 is general intent only.
United States v. Hillsman, 522 F.2d 454 (7th Cir. 1975) and United States v. Perkins, 488 F.2d 652 (1st Cir. 1973)—Both involved defendants unaware they were assaulting federal officers, unlike Parrot who conceded that point; thus they did not support his proposed instruction.
United States v. Facteau, 89 F.4th 1 (1st Cir. 2023) and United States v. Nieves‐Meléndez, 58 F.4th 569 (1st Cir. 2023)—Outlined the plain‐error standard for unpreserved instructional challenges.

Legal Reasoning

The First Circuit’s key legal reasoning rests on these points:

General vs. specific intent. Under Feola and Carter, § 111 is satisfied by a general intent to assault; it does not require knowledge of the officer’s official duties or legal authority (e.g., a warrant). Parrot’s proposed instruction would have effectively imposed a specific‐intent requirement.
Mistake of fact exception. The Supreme Court in Feola acknowledged that an honest mistake of fact—such as not knowing the assailant is an officer or misunderstanding the officer’s purpose—could negate criminal intent. But Parrot did not present evidence of a mistake under Feola’s rubric (he knew the victim was an officer and did not claim he acted under a reasonable misimpression of unlawful force).
Instructional error standard. Under Denson, a refused instruction must be substantively correct. Because § 111 only requires general intent, Parrot’s proposed instruction misstated the law and was properly rejected.
Self‐defense instruction. Parrot’s challenge to the self‐defense instruction was not preserved and fails plain‐error review in the absence of an argument below or evidence of excessive force by the officers.

Impact

United States v. Parrot reaffirms the broad reach of § 111’s general‐intent requirement. Defense counsel must carefully tailor jury instructions to avoid importing specific‐intent elements where the statute does not require them. The decision also highlights that mistake‐of‐fact defenses under § 111 must be grounded in evidence of a reasonable, honest misunderstanding of an officer’s identity or purpose, not merely an absence of knowledge of procedural details such as the existence of a warrant.

For future cases, trial courts should:

Grant mistake‐of‐fact instructions only when there is evidentiary support for an honest, reasonable misunderstanding of an officer’s identity or facially coercive conduct.
Decline instructions that conflate knowledge of officer status with knowledge of legal authority to act.
Insist on precise, statute‐conforming language in self‐defense and intent instructions to preserve issues for appeal.

Complex Concepts Simplified

General intent vs. specific intent: General intent requires only that the defendant intended to do the act (e.g., pushing someone). Specific intent requires that the defendant intended a further legal consequence (e.g., knowing that person was a federal officer on official duty).
Mistake of fact: A defendant’s honest and reasonable belief in a fact that, if true, would make his conduct non‐criminal (e.g., believing the assailant is not an officer or is about to harm him).
Plain‐error review: Appellate review of unpreserved errors requires showing the error was clear, affected substantial rights, and seriously impaired the fairness or integrity of proceedings.

Conclusion

United States v. Parrot clarifies that under 18 U.S.C. § 111 a defendant need only possess the general intent to commit an assault; knowledge of distinct legal prerequisites—such as a warrant authorizing the officer’s entry—is unnecessary. The First Circuit’s decision emphasizes fidelity to statutory intent requirements, proper limitation of mistake‐of‐fact defenses, and strict adherence to preserved trial objections for appellate review. This precedent will guide trial courts and practitioners in crafting and evaluating jury instructions in federal‐officer assault cases, ensuring that juries are neither misled nor over‐instructed on elements the statute does not demand.