In the 1974 case United States v. Park, the Supreme Court ruled that a corporate officer could be held criminally responsible for violations of the Federal Food, Drug and Cosmetic Act committed by his company even if he did not participate in or know about those violations. The defendant was Acme Markets' president John R. Park who had been convicted of storing food under unsanitary conditions at one of their warehouses after an FDA inspection revealed rodent infestation problems which were not rectified despite warnings from FDA officials to Mr. Park himself. In its decision, the court emphasized that it is a strict liability crime where responsibility lies with individuals whose failure to exercise authority resulted in statutory violation regardless of whether they intended any wrongdoing or knew about it.

In the dissenting opinion for United States v. Park, Justice William O. Douglas argued that the majority's decision to hold a CEO criminally liable for violations of food safety laws committed by his company was unjust and overreaching. He contended that it is unreasonable to expect a corporate executive to have detailed knowledge of every operation within their organization, especially in large corporations with thousands of employees spread across multiple locations. Furthermore, he expressed concern about the potential implications of this ruling on other areas of law where strict liability might be applied unfairly or excessively against individuals who lack direct control over all aspects of their businesses' operations.