What is the test for possession of goods stolen from interstate commerce?

This instruction is, of course, entirely proper with regard to the substantive crime of possession of goods stolen from interstate commerce. But, as we held in United States v. Fields, 466 F.2d 119, 121 (2d Cir. 1972), a necessary component of conspiracy to violate 18 U.S.C. 659 is the knowledge not only that the goods were stolen, but that they were stolen from an interstate shipment. The distinction between the scienter component of the conspiracy and substantive charges arises from the notion that although an individual may commit some crimes unwittingly, he cannot conspire to commit a specific crime unless he is aware of all the elements of the crime. In Learned Hand's classic phrase,

United States v. Crimmins, 123 F.2d 271, 273 (2d Cir. 1941).