Cheek v. U.S.
SCOTUS - 1991
- D was an airplane pilot who believed that the federal income tax requirements were unconstitutional. He attended various seminars about this topic and sat in on various tax evasion trials.
- D stopped paying income taxes.
- D was indicted on willfully failing to file a tax return and willfully attempting to evade his income tax.
- D honestly believed that he didn't have to pay income tax and represented himself at trial.
- The jury was instructed that D was guilty if his belief was made in good faith but was unreasonable.
- District Court found D guilty.
- COA affirmed, D guilty.
- SCOTUS reversed, remanded for new trial.
- Does an honest but unreasonable belief negate a statute's requirement for willfulness?
- A claimed good-faith belief need not be reasonable in order to be considered as a defense.
- D was aware of his duty to file a return and to treat wages as income.
- While the tax code is complex, the complexities are not reason for D to believe that the rules were unconstitutional.
- Instead, this reveals that the D had full knowledge of the issues at hand and believed that the tax provisions were unenforceable.
- The trial court's instruction about unreasonable beliefs was incorrect and grounds for reversal.
- It was error to instruct the jury to disregard evidence of D's understanding that he was not a person required to pay income taxes, as crazy as this belief is.
- The more unreasonable the belief, however, the more likely the jury will consider them to be nothing more than simple disagreement with known legal duties.
- Blackmun: This will encourage people to hold crazy beliefs about tax laws just to get out of paying taxes.
- On remand, Cheek was convicted on all counts.