Ratzlaf v. United States

510 U.S. 135, 114 S. Ct. 655 (1994)

 

RULE:

To establish that a defendant "willfully violated" the anti-structuring law, the government must prove the defendant acted with knowledge that his conduct was unlawful.

FACTS:

Petitioner attempted to pay a $ 100,000 casino debt in cash. A casino official informed petitioner that transactions involving more than $ 10,000 in cash had to be reported to state and federal authorities. Informed that banks, too, were required to report cash transactions in excess of $ 10,000 pursuant to 31 U.S.C.S. § 5313, petitioner purchased cashier's checks, each for less than $ 10,000 and each from a different bank. He then delivered those checks as payment on the debt. Based on that act, petitioner was criminally charged with structuring transactions to evade the banks' obligation to report cash transactions exceeding $ 10,000 in violation of 31 U.S.C.S. §§ 5322(a) and 5324(3). He was convicted for the charge and the conviction affirmed by the United States Court of Appeals. The case was appealed to the Supreme Court of the United States.

ISSUE:

Was the conviction proper?

ANSWER:

No.

CONCLUSION:

The judgment of the court below affirming petitioner's conviction under those statutes was reversed on appeal because the jury had been improperly instructed that all the government had to prove was defendant's knowledge of the banks' reporting obligation and his attempt to evade that obligation. The Supreme Court found the statutes required the government to also prove defendant acted with knowledge that his conduct was unlawful. The trial court's instruction to the contrary was therefore error.

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