Cheek v. United States
112 L. Ed. 2d 617 · Supreme Court of the United States · 1991
Facts
John L. Cheek, an American Airlines pilot, filed federal income tax returns through 1979 but ceased thereafter, claiming increasing withholding allowances and exempt status on W-4 forms from 1981 to 1984. His income always exceeded the minimum for filing, and he unsuccessfully sought a refund of 1982 withheld taxes. Cheek was indicted for six counts of willfully failing to file tax returns and three counts of willfully attempting to evade taxes. He had been involved in civil cases challenging tax laws, where his arguments were deemed frivolous, and attended seminars promoting the belief that the tax system is unconstitutional. Cheek testified that he sincerely believed the tax laws were unconstitutionally enforced and his actions were lawful, thus lacking the required willfulness.
Procedural history
Petitioner was indicted and convicted by a jury after the trial court instructed that only objectively reasonable beliefs negate willfulness and that constitutional beliefs are irrelevant. The Seventh Circuit affirmed, upholding the objective reasonableness standard for negating willfulness. The Supreme Court granted certiorari due to conflicting appellate decisions on the interpretation of "willfully."
Issue
Does a good-faith misunderstanding of the law or a good-faith belief that one is not violating the law, to negate willfulness in criminal tax offenses, need to be objectively reasonable? Are a defendant's beliefs about the unconstitutionality of tax statutes relevant to the issue of willfulness?
Holding
A good-faith misunderstanding of the law or a good-faith belief that one is not violating the law does not need to be objectively reasonable to negate willfulness. However, a defendant's views about the validity or unconstitutionality of the tax statutes are irrelevant to the issue of willfulness.
Rule
The term "willfully" in federal criminal tax statutes means a voluntary, intentional violation of a known legal duty. To prove willfulness, the Government must prove the law imposed a duty, the defendant knew of this duty, and voluntarily and intentionally violated it. A defendant's good-faith misunderstanding of the law or a good-faith belief that they are not violating the law negates the knowledge component of willfulness, regardless of whether that belief is objectively reasonable, due to the complexity of tax laws. However, a defendant's belief that the tax laws are unconstitutional does not negate willfulness, as it reflects knowledge of the law but disagreement with its validity, not a misunderstanding of the duty itself.
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