Cheek v. United States case brief

Cheek v. United States
498 U.S. 192 (1991)

Facts:
-A pilot did not file taxes because he thought it was unconstitutional.
-Each of the crimes he was charged with required that the defendant acted willfully.
-The jury was instructed that a defense to willfulness could be established by showing a good faith misunderstanding of the law, but not simply a disagreement with the law.

Procedural History:
-The trial court said that a mere opinion that a law is unconstitutional or a disagreement with tax policies is not a good faith misunderstanding of the law.
-Unreasonable belief was said to not be a defense of obligation to pay taxes. Jury returned verdict of guilty.
-∆ argued that the trial court erred by instructing the jury to use an objective standard in determining willfulness.

Issue:
Does a defendant’s good faith belief that he was acting lawfully have to be objectively reasonable in order for it to defeat the willful requirement of a criminal law violation?

Holding: No.

Reasoning:
-The court has softened the “ignorance of the law is not an excuse” adage.  In terms of criminal tax crimes, there has to be a specific intent element. A defendant was entitled to an instruction that took into account a good faith belief. Govt. is required to make a three part showing:

1. law imposed a duty on the defendant
2. defendant must have known of the duty
3. prosecution must show that the defendant voluntarily and willfully violated the duty

The question here is (2).
-Even if his beliefs are unreasonable, but the jury could find that ∆ did not believe that the IRS could treat wages as income, then the governemnt would not have proved willfulness. 
-However, arguing that the provisions of the tax code are unconstitutional does not demonstrate an innocent mistake due to the complex nature of the tax code. Instead, it shows a thorough understanding of the code.
-A defendant’s views about the validity of a statute are irrelevant to his willfulness. Thus, his request for an instruction that he believed they were unconstitutional was properly disregarded.
-His beliefs that wages were not income and that he was not a tax payer under the code were relevant and should be considered by the jury.


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