In Morissette v. United States, 342 U.S. 246 (1952), the Supreme Court reversed the defendant's conviction for converting government personal property (spent artillery shells) into personal use as scrap metal on the grounds that defendant, believing that the scrap was abandoned, had no criminal intent. In reviewing the history of criminal intent, the Court traced "crime, as a compound concept, generally constituted only from the concurrence of an evil-meaning mind with an evil-doing hand" (Morissette at 251) to the nineteenth century common law, early American settlers and eighteenth century England. Thus, except for specifically identified strict liability crimes, a defendant must be blameworthy in mind before he can be found guilty, a concept courts have expressed over time through various terms such as mens rea, scienter, malice, aforethought, guilty knowledge, and the like (see Morissette at 252 1952).