Cheek v. United States

Background

A commercial airline pilot stopped filing federal income tax returns after 1979, claimed many withholding allowances, and was indicted for willfully failing to file returns and attempting to evade taxes. At trial the judge told the jury that a good-faith misunderstanding of the law could negate willfulness only if it was objectively reasonable. The Seventh Circuit affirmed that rule, and the Supreme Court agreed to resolve the disagreement among appeals courts about the proper standard for “willfulness.”

Reasoning

The Court explained that criminal tax offenses require proof that the defendant knew of a legal duty and voluntarily violated it. The Court held that a defendant’s sincere belief that he was not violating the tax laws can negate that knowledge element even if the belief is not objectively reasonable, so juries must be allowed to consider such claims. The Court also said a different rule applies to claims that the tax laws are unconstitutional: those claims show a studied conclusion of invalidity and need not be presented to the jury as a defense. The Court therefore rejected the Seventh Circuit’s blanket requirement of objective reasonableness and vacated its judgment.

Real world impact

The decision lets juries weigh a defendant’s subjective, honest misunderstandings about tax duties, even if courts find those beliefs unreasonable. At the same time, it clarifies that asserting the tax laws are unconstitutional is not the same kind of innocent misunderstanding and can be excluded. The case is sent back for further proceedings under these clarified rules.

Dissents or concurrances

Justice Scalia agreed with the judgment but warned the Court’s rule departs from earlier cases and may expand criminal liability. Justice Blackmun (joined by Justice Marshall) dissented, arguing the Court should have affirmed because basic tax facts like wages as income are well established.