Cheek v. United States
United States Supreme Court
498 U.S. 192 (1991)
Relevant factsFree
John Cheek (defendant), influenced by an anti-tax group claiming federal tax laws were unconstitutional, stopped filing returns and was charged with willfully failing to file, a specific-intent crime. At trial, Cheek argued he sincerely believed he owed no taxes on his wages; the judge instructed the jury that an honest but unreasonable belief does not negate willfulness and that persistent refusal to accept the law is not good-faith misunderstanding. Cheek was convicted, and the court of appeals affirmed.
IssueFree
Whether a purportedly good-faith misunderstanding of the law must be objectively reasonable to negate the specific-intent requirement of willfulness under criminal tax statutes.