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2025 Supreme(US)(ca1) 31

COURT OF APPEALS FOR THE FIRST CIRCUIT
United States – Appellant
Versus
Parrot – Respondent



No. 24-1563 UNITED STATES,

Appellee,

v.

ALAN HOWELL PARROT,

Defendant, Appellant.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MAINE

[Hon. Lance E. Walker, U.S. District Judge]

Before Barron, Chief Judge, Breyer,* Associate Justice, and Kayatta, Circuit Judge.

Kurt C. Peterson, with whom Walter F. McKee, Matthew D. Morgan, and McKee Morgan, LLC, P.A., were on brief, for appellant. Brian S. Kleinbord, Assistant United States Attorney, with whom Darcie N. McElwee, United States Attorney, was on brief, for appellee.

March 21, 2025

* Hon. Stephen Breyer, Associate Justice (Ret.) of the Supreme Court of the United States, sitting by designation. BREYER, Associate Justice. A federal statute, 18 U.S.C. § 111, makes it unlawful to "forcibly assault[]" a federal officer. The defendant in this case, Alan Parrot, concedes that he "pushed" an FBI agent with his foot when she tried to enter his home. He also concedes that he knew, at the time of the altercation, that the agent was a federal officer. But he insists that he did not know that the officer had a search warrant to enter his home. He accordingly argues that his conviction was improper because the jury should have been instructed that his ignorance of that fact made a difference.

There may be situations in which a person's lack of knowledge about facts in the world makes a conviction under § 111 improper -- even where the assailant is aware that his victim is a federal officer. Cf. United States v. Feola, 420 U.S. 671, 686 (1975). But, in our view, the instructions to which Parrot points on appeal do not speak to that kind of factual ignorance. We consequently affirm his conviction.

I.

The record indicates that the relevant facts are the following: One morning three FBI agents showed up at Parrot's house. They were there to execute a search warrant. The encounter got off to a good start. Parrot came to his front door, the officers displayed their credentials, and they talked for over an hour. But Parrot kept goats on the property; the goats started

- 2 - to nibble on the officers' pants, ankles, and bags; and the officers consequently asked Parrot if they could talk to him behind the house, where there were no goats. Parrot agreed, and they all moved to the rear of the residence. At this point, Parrot was standing inside his house while the officers stood on steps outside. Between them was an open sliding glass door.

Matters then took a turn for the worse. After about fifteen minutes, the conversation shifted to "issues related to the search warrant." One of the officers told Parrot that he had legal paperwork he wanted to show him -- referring, the officer testified, to the search warrant he had brought with him. Parrot began to appear upset. He told the officers that the conversation was over, and he tried to shut the sliding glass door. The officers did not want the conversation to end. In particular, they wanted to avoid Parrot barricading himself inside his house. So one of the officers -- Special Agent Angell -- reached into the house and grabbed Parrot's arm to prevent him from closing the door. Another stepped inside the doorframe to stop the door from closing.

During the ensuing scuffle Parrot kicked Special Agent Angell in the stomach -- or, as he testified, "pushed her with the flat of [his] foot" -- injuring her. The officers eventually removed Parrot from his

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