Dow Prino, Pawnbroker, D/B/A Dow's v. William E. Simon, Secretary of the Treasury

The Secretary of the Treasury denied Prino’s application for renewal of his license as a dealer in firearms under the Gun Control Act of 1968, 18 U.S.C. §§ 921 et seq. based upon an administrative determination that Prino had “willfully” violated the Act in several respects, a statutory ground for denial. 18 U.S.C. § 923(d)(1)(C). Prino sought judicial review under 18 U.S.C. § 923(f)(3), and the district court concluded that the application was properly denied because of willful violations.

On this appeal Prino contends that the willfulness of violation required to deny a license should be…