Law School Case Brief
Ratzlaf v. United States - 510 U.S. 135, 114 S. Ct. 655 (1994)
To establish that a defendant "willfully violated" the anti-structuring law, the government must prove defendant acted with knowledge that his conduct was unlawful.
The case at hand involved several interrelated provisions of the Bank Secrecy Act (31 U.S.C.S. §§ 5311 et seq.). Pursuant to 31 U.S.C.S. § 5313(a), as implemented by the United States Secretary of the Treasury, banks and other financial institutions were required to report any cash transaction that exceeded $ 10,000. Under former 31 U.S.C.S. § 5324(3) (recodified as 31 U.S.C.S. § 5324(a)(3) without substantive change), it was illegal to break up, into two or more separate transactions, a single cash transaction with a bank or other financial institution for the purpose of evading the reporting requirement of § 5313. In addition, a person who "willfully" violated the antistructuring provision of § 5324 was subject to criminal penalties. Defendant Waldemar Ratzlaf attempted to pay a Nevada casino $ 100,000 in cash as part of his gambling debt and was informed by a casino official that all transactions involving more than $ 10,000 in cash had to be reported to state and federal authorities, but that a cashier's check for the full amount due would not trigger any reporting requirement. When defendant was informed that banks also were required to report cash transactions in excess of $ 10,000, defendant purchased a number of cashier's checks, each of which was for less than $ 10,000 and rom different banks. Defendant was charged by a federal grand jury with violating § 5322(a) and § 5324(3). At trial in the United States District Court for the District of Nevada, the trial judge instructed the jury that under § 5322(a) and § 5324(3), the government (1) had to prove defendant's knowledge of the banks' reporting obligation and defendant's attempt to evade such obligation; but (2) did not have to prove that defendant knew that his structuring of the cash transactions was unlawful. Defendant was convicted. On appeal, the United States Court of Appeals for the Ninth Circuit, in affirming, upheld the district court's construction of § 5322(a) and § 5324(3). The Supreme Court of the United States granted defendant's petition for certiorari.
For purposes of § 5322(a), to prove that an accused has "willfully" violated §5324(3), must the federal government prove that the accused acted with knowledge that his conduct was unlawful?
On certiorari, the Supreme Court of the United States reversed and remanded. In an opinion by Ginsburg, J., joined by Stevens, Scalia, Kennedy, and Souter, JJ., it was held that in order to establish, for purposes of § 5322(a), that an accused had "willfully" violated § 5324(3), the government was required to prove that the accused acted with knowledge that his conduct was unlawful, because (1) the willfulness requirement of § 5322(a), when applied to other provisions of the Bank Secrecy Act, consistently had been read to require both knowledge of the reporting requirement and a specific intent to commit the crime; (2) there was strong cause to construe the single formulation of § 5322(a) the same way each time the formulation was called into play; (3) currency structuring was not so obviously evil or inherently bad that the willfulness requirement of § 5322(a) was satisfied irrespective of an accused's knowledge of the illegality of structuring; (4) the legislative history of § 5322(a) would not be resorted to, as the statutory text was clear; (5) any doubt that the willfulness requirement of § 5322(a) was ambiguous as applied to § 5324 would be resolved in favor of the accused; and (6) Congress had legitimately decreed in § 5322(a) and the provisions it controlled that ignorance of the law was a defense.
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