United States v. Stephen Gustus, 926 F.3d 1037

On Dec. 21, 2016, Postal employee Julio Gonzalez was tackled from behind and assaulted by Stephen Gustus; a confrontation in Gonzalez's mail truck led to additional blows and Gustus fleeing.
Police located Gustus; he was noncompliant, exhibited signs of intoxication, and was pepper-sprayed and arrested.
Gustus was charged under 18 U.S.C. § 111(a)(1) for assaulting a federal employee, pleaded not guilty, and sought to present a voluntary-intoxication defense.
The district court granted the government’s motion in limine, excluding the intoxication defense based on Eighth Circuit precedent treating § 111 as a general-intent crime.
A jury convicted Gustus; he was sentenced to time served and two years supervised release with a special condition (Special Condition 5) requiring substance-abuse treatment and abstention from alcohol during supervision.
On appeal Gustus challenged (1) exclusion of the intoxication defense, (2) sufficiency of the evidence, and (3) the breadth of Special Condition 5; the court affirmed the conviction, reversed the written special condition as broader than the oral pronouncement, and remanded for clarification or a mootness determination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 111(a)(1) permits a voluntary-intoxication defense	Gov: Hanson controls; § 111 is a general-intent crime so intoxication defense unavailable	Gustus: Later decisions indicate § 111 requires specific intent; intoxication would negate intent	Court: Follow Hanson; intoxication defense unavailable for § 111(a)(1) offenses (general-intent)
Sufficiency of the evidence for voluntariness/intent	Gov: Evidence (witness testimony, officer observations) proves voluntary and intentional assault	Gustus: Intoxication and alleged witness inconsistencies negate voluntariness and credibility	Court: Evidence sufficient; credibility is for the jury; affirm conviction
Whether Special Condition 5 exceeds oral pronouncement	Gov: Written condition tracks oral order	Gustus: Written condition broader (abstinence during entire supervision) than oral limitation (only during treatment)	Court: Written condition broader; reverse and remand for district court to determine mootness or clarify the alcohol prohibition
Whether earlier conflicting precedents should be overruled	Gov: Hanson (earlier) binds panel	Gustus: Manelli and others suggest specific-intent treatment; intoxication defense should apply	Court: Bound by Hanson under Mader; panel cannot overrule it; concurrence urges en banc review

United States v. Hanson, 618 F.2d 1261 (8th Cir. 1980) (holds § 111 assault is a general-intent crime; intoxication defense unavailable)
United States v. Manelli, 667 F.2d 695 (8th Cir. 1981) (characterizes § 111 assault as requiring specific intent)
United States v. Kenyon, 481 F.3d 1054 (8th Cir. 2007) (voluntary-intoxication defense applies to specific-intent crimes)
Feola v. United States, 420 U.S. 671 (U.S. 1975) (statute requires intent to assault, not intent to assault a federal officer)
Mader v. United States, 654 F.3d 794 (8th Cir. 2011) (earlier panel precedent binds later panels)
United States v. James, 792 F.3d 962 (8th Cir. 2015) (remand to clarify or modify supervis ed-release special condition)