Fields v. United States
United States Court of Appeals for the District of Columbia
164 F.2d 97 (1947)
Relevant factsFree
Fields (defendant) was subpoenaed by the U.S. House of Representatives to testify and produce documents relevant to a congressional investigation, and was charged with contempt for refusing to comply. He was acquitted on one count but convicted on the other, which required proof he acted willfully. He appealed, arguing the jury should have been told willfulness required an evil or bad purpose behind his refusal.
IssueFree
Whether the term willfully, as used in a federal criminal statute, requires proof that the defendant acted with an evil or bad purpose.