United States v. Murdock

Background

A taxpayer was indicted for refusing to answer revenue agents about deductions and the names of people he paid on his 1927 and 1928 returns. He told agents he feared self-incrimination and said that fear stemmed from possible state prosecutions. He was convicted at trial, the appeals court reversed, and the case reached the Court to decide what the tax laws require for a criminal refusal to supply information.

Reasoning

The Court focused on whether the word "willfully" in the federal tax laws means more than simply acting voluntarily. The majority explained that Congress intended criminal liability only when a person acted with wrongful or bad-faith intent, not because of an honest mistake or a sincere belief about the law. Because the trial judge had told the jury the defendant was guilty beyond reasonable doubt and refused to let the jury consider the defendant’s good-faith fear of state prosecution, the Court held the jury should have decided whether the refusal showed evil intent.

Real world impact

The decision means prosecutors must prove a wrongful, blameworthy mental state to convict someone for refusing to supply tax-related information. Juries must be allowed to weigh a witness’s honest belief that answering would incriminate them under state law. The ruling affirmed the appeals court’s reversal and protects defendants from convictions when their silence stems from a genuine fear of state prosecution rather than bad intent.

Dissents or concurrances

Two Justices would have reversed the appeals court and upheld the conviction, indicating disagreement about how to apply the statute and judge’s instructions.