| Court: | United States Supreme Court |
| Facts: | The defendant was involved in a complicated accounting scheme to defraud FHA and HUD via bogus loan applications and strawman sales. I don't pretend to follow the financial elements of the crime, but the facts of the case are not disputed, to my great relief. The statute 18 §1001 says that for the crime to take place, the defendant must knowingly make material false statements (apparently it is OK to tell immaterial fibs). The judge's instructions to the jury required them not to consider whether the defendant's false statements were material to the fraud, and the appeal concerns whether or not that deprived the defendant of due process with respect to this element of the crime, whatever it was (making false statements on federal loan documents). |
| Posture: | US District Court of Montana convicted. Appealed on the basis of bogus jury instruction, reversed by the Ninth Circuit Court. |
| Issue: | Whether "materiality" is an element of a crime that must be determined by a jury. |
| Holding: | Affirms the reversal: materiality is an element of the crime, and a jury must find a defendant guilty beyond reasonable doubt of all elements of the crime in order to convict. |
| Rule: | The Constitution gives a criminal defendant the right to have a jury determine, beyond reasonable doubt, the defendant's guilt of every element of the crime charged. This includes applying the law to the facts in question. |
| Reasoning: | Everyone agrees that materiality is an element of the crime in question, and what "materiality" is. The prosecution alleges that the jury is just a finder of fact, not an answerer of legal questions. Scalia mocks this with commentary about law textooks, but points out that mixtd questions of law and fact are commonly resolved by juries, not judges, and that precedent dictates that it be so. If it were not so, the jury would be deprived of its role in determining guilt or innocence. |
| Dicta: | None. |