Neder v. United States
United States Supreme Court
527 U.S. 1 (1999)
Relevant factsFree
Neder (defendant) was tried for tax fraud for failing to report loan proceeds as income. The trial judge incorrectly instructed the jury that it did not need to decide whether Neder's false statements were "material," telling jurors that materiality was not a question for them. Neder was convicted and appealed, arguing the flawed instruction was a structural error requiring automatic reversal, regardless of whether it actually affected the verdict.
IssueFree
Whether a jury instruction that omits an element of a crime can be harmless error, rather than requiring automatic reversal, when the omitted element was undisputed and supported by overwhelming evidence.