United States v. Fowler

Fowler (defendant), who had stopped filing tax returns decades earlier, was indicted for willfully failing to pay income tax for several years and chose to represent himself and testify at trial. The court refused to let him testify because he would not take the oath or make any direct affirmation that he would tell the truth, offering instead only indirect statements like 'I am a truthful man' rather than the simple affirmation the court proposed. Fowler was convicted on all counts and, after obtaining appellate counsel, argued the trial court erred by barring him from testifying.