United States v. Gaudin

Background

In the 1980s a real-estate investor sold properties using FHA‑insured loans and filled out HUD forms with inflated appraisals and misstated closing costs. At trial the judge told the jury that materiality was for the court to decide and instructed that the statements charged were material. The jury convicted the investor under 18 U.S.C. §1001, but the Ninth Circuit reversed and the Supreme Court agreed to review whether materiality must be decided by the jury.

Reasoning

The Court asked whether the Constitution requires a jury to find every element of a crime beyond a reasonable doubt and concluded it does. Relying on the Fifth and Sixth Amendments, historical practice, and prior cases, the Court rejected the Government’s arguments that materiality is a judge‑only legal question or protected by stare decisis. The Court held that materiality is an element the jury must decide and that taking it away from the jury infringed the defendant’s constitutional rights. The Court affirmed the Ninth Circuit.

Real world impact

Prosecutors must present evidence of materiality to juries in false‑statement cases involving federal agencies, and convictions where judges alone decided materiality may be overturned. The decision affects prosecutions under §1001 and similar cases that turn on mixed questions of law and fact. The Court did not resolve whether materiality is an element of every clause of §1001.

Dissents or concurrances

A concurring opinion agreed with the judgment but emphasized the Government’s concessions and noted that the Court left open some statutory questions and harmless‑error issues.