Law School Case Brief
Fields v. United States - 82 U.S. App. D.C. 354, 164 F.2d 97 (D.C. Cir. 1947)
The meaning of the word "willful" depends in large measure upon the nature of the criminal act and the facts of the particular case. It is only in very few criminal cases that "willful" means "done with a bad purpose." Generally, it means no more than that the person charged with the duty knows what he is doing.
On Aug. 8, 1946, a subpoena was issued summoning appellant Fields to appear before the select committee of the United States House of Representatives to investigate the disposition of surplus property. In the course of his testimony, Fields turned over a document showing payment to a "John Doe." Fields failed to respond to repeated Congressional requests for additional documentation to explain the expenditure. As a result, Field was charged in federal district court under an indictment with violating 2 U.S.C.S. § 192, which provided that any person who is summoned by either House of Congress who willfully makes default, refuses to answer any question pertinent to the question under inquiry, shall be deemed guilty of a misdemeanor, punishable by a fine of not more than $ 1,000 nor less than $ 100 and imprisonment in a common jail for not less than one month nor more than twelve months. After a trial, a jury found Fields guilty, and judgment on the verdict was entered on the verdict. Fields appealed.
Did the word "willfully" as used in 2 U.S.C.S. § 192 imply an evil or bad purpose as requisite element for conviction under the statute?
The appellate court affirmed the district court's judgment. The court ruled, inter alia, that the apparent objective of § 192 would be largely defeated if, as Fields contended, a person could appear before a Congressional investigating committee and by professing willingness to comply with its requests for information escape the penalty for subsequent default. The district court charged the jury that: The word "willful" does not mean that the failure or refusal to comply with the order of the committee must necessarily be for an evil or a bad purpose. The reason or the purpose of failure to comply or refusal to comply is immaterial, so long as the refusal was deliberate and intentional and was not a mere inadvertence or an accident. The court ruled that the jury instruction was proper in its definition of "willful" as used in § 192.
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