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Criminal Law Keyed to Capers
Cheek v. United States
Citation:
498 U.S. 192 (1991)Facts
Petitioner John L. Cheek has been a pilot for American Airlines since 1973. He filed federal income tax returns through 1979 but thereafter ceased to file returns. Petitioner’s income during this period at all times far exceeded the minimum necessary to trigger the statutory filing requirement. The government indicted Cheek for 10 violations of federal law. In the course of its instructions, the trial court advised the jury that to prove “willfulness” the Government must prove the voluntary and intentional violation of a known legal duty, a burden that could not be proved by showing mistake, ignorance, or negligence. The court further advised the jury that an objectively reasonable good-faith misunderstanding of the law would negate willfulness, but mere disagreement with the law would not. The court described Cheek’s beliefs about the income tax system and instructed the jury that if it found that Cheek honestly and reasonably believed that he was not required to pay income taxes or to file tax returns, a not guilty verdict should be returned.
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