Willful Blindness Instructions in Criminal Tax Cases: The Third Circuit's Stadtmauer Ruling

By Jeremy D. Frey (White Collar and Corporate Investigations Practice) and Paul D. Pellegrini (Tax Practice) In United States v. Stadtmauer , 620 F.3d 238 (3d Cir. N.J. 2010) , the Third Circuit Court of Appeals recently upheld a willful blindness jury instruction that applied to a defendant's...

United States v. Stadtmauer, 620 F.3d 238 (3d Cir. N.J. 2010)

In affirming the district court's judgment of conviction, the court principally considered whether the district court erred in giving a "willful blindness" instruction. Affirming, the court concluded that a willful blindness instruction that applied to a defendant's knowledge of the...