November 10, 2013

Cheek v. United States | Case Brief Law Student - 498 U.S. 192 (1991) - US Supreme Court

FACTS: Cheek was convicted for not filing and paying federal income taxes.  He claimed he sincerely believed that under the tax laws he owed no taxes and the tax laws themselves were unconstitutional.

HISTORY:
Judge instructed the jury among other things that "an honest but unreasonable belief is not a defense and does not negate willfulness."  He was convicted and appealed.

ISSUE:
Is failure to know that you are breaking a law a defense?

HOLDING: Yes (?)

RATIONALE: The instructions of the judge in regards to deciding if the "good faith belief must be objectively reasonable" was wrong.

- "... the standard for the statutory willfulness requirement is the voluntary intentional violation of a known legal duty."

DISPOSITION:
Judgement of the Court of appeals is vacated and the case remanded for further proceedings consistent with the opinion.

COMMENTS:
- court wants to avoid criminalizing otherwise innocent conduct