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United States v. Gaudin
{{Infobox SCOTUS case {{Infobox SCOTUS case
| Litigants = United States v. Gaudin | Litigants = United States v. Gaudin
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}} }}


United States v. Gaudin is a ] case in which the Court held the trial judge's refusal to submit the question of "]" to the jury was unconstitutional. If materiality is a required element of the offense, it must be presented to the jury, which must determine it beyond a reasonable doubt for a conviction.<ref name=":0">{{Cite web |title=United States v. Gaudin, 515 U.S. 506 (1995) |url=https://supreme.justia.com/cases/federal/us/515/506/ |access-date=2024-12-26 |website=Justia Law |language=en}}</ref> '''United States v. Gaudin''' is a ] case in which the court held the ]'s refusal to submit the question of "]" to the ] was unconstitutional. If materiality is a required element of the offense, it must be presented to the jury, which must determine it ] for a ].<ref name=":0">{{Cite web |title=United States v. Gaudin, 515 U.S. 506 (1995) |url=https://supreme.justia.com/cases/federal/us/515/506/ |access-date=2024-12-26 |website=Justia Law |language=en}}</ref>
== Background and procedural history == == Background and procedural history ==
In the 1980s, Gaudin engaged in real estate transactions using FHA-insured loans from HUD. His scheme involved inflating property appraisals, selling properties to "straw buyers," and repurchasing them for profit. Many loans defaulted, and Gaudin was charged with making false statements under 18 U.S.C. § 1001. In the 1980s, Gaudin engaged in real estate transactions using ] from ]. His scheme involved inflating property appraisals, selling properties to "straw buyers," and repurchasing them for profit. Many loans defaulted, and Gaudin was charged with ] under 18 U.S.C. § 1001.


At trial, the United States District Court for the District of Montana instructed the jury to determine whether Gaudin's statements were false, but decided alone the issue of materiality, a requirement for conviction under §1001, ruling it was not for the jury to consider. The jury convicted Gaudin.<ref name=":1">{{Cite web |title=United States of America, Plaintiff-appellee, v. Michael E. Gaudin, Defendant-appellant, 997 F.2d 1267 (9th Cir. 1993) |url=https://law.justia.com/cases/federal/appellate-courts/F2/997/1267/382131/ |access-date=2024-12-26 |website=Justia Law |language=en}}</ref> At trial, the ] instructed the jury to determine whether Gaudin's statements were false, but decided itself the issue of materiality, a requirement for conviction under §1001, ruling materiality was not for the jury to consider. The jury convicted Gaudin.<ref name=":1">{{Cite web |title=United States of America, Plaintiff-appellee, v. Michael E. Gaudin, Defendant-appellant, 997 F.2d 1267 (9th Cir. 1993) |url=https://law.justia.com/cases/federal/appellate-courts/F2/997/1267/382131/ |access-date=2024-12-26 |website=Justia Law |language=en}}</ref>


Gaudi appealed. In 1993, the United States Court of Appeals for the Ninth Circuit reversed.<ref name=":1" /> On rehearing in 1994, the Court of Appeal held that taking the question of materiality from the jury violated the Fifth and Sixth Amendments.<ref>{{Cite web |title=United States of America, Plaintiff-appellee, v. Michael E. Gaudin, Defendant-appellant, 28 F.3d 943 (9th Cir. 1994) |url=https://law.justia.com/cases/federal/appellate-courts/F3/28/943/580953/ |access-date=2024-12-26 |website=Justia Law |language=en}}</ref> Gaudi appealed. In 1993, the ] reversed.<ref name=":1" /> On rehearing in 1994, the Court of Appeals held that taking the question of materiality from the jury violated the ] and ] of the ].<ref>{{Cite web |title=United States of America, Plaintiff-appellee, v. Michael E. Gaudin, Defendant-appellant, 28 F.3d 943 (9th Cir. 1994) |url=https://law.justia.com/cases/federal/appellate-courts/F3/28/943/580953/ |access-date=2024-12-26 |website=Justia Law |language=en}}</ref>


== Opinion of the Court == == Opinion of the court ==
Justice Scalia delivered the opinion of the Court and affirmed the judgment of the Court of Appeals.<ref name=":0" /> In June 1995, ] delivered the opinion of the Supreme Court and affirmed the judgment of the Court of Appeals.<ref name=":0" />


Relying on the Fifth and Sixth Amendments, the Court held that the Constitution provisions "require criminal convictions to rest upon a jury determination that the defendant is guilty of every element of the crime with which he is charged, beyond a reasonable doubt." The trial judge's refusal to allow the jury to pass on the "materiality" of Gaudin's false statements infringed that right.<ref name=":0" /> Relying on the Fifth and Sixth Amendments, the Court held that the Constitution provisions "require criminal convictions to rest upon a jury determination that the defendant is guilty of every element of the crime with which he is charged, beyond a reasonable doubt." The trial judge's refusal to allow the jury to determine the materiality of Gaudin's false statements infringed that right.<ref name=":0" />


Chief Justice Rehnquist, Justice O'Connor, and Justice Breyer concurred.<ref name=":0" /> ], ], and ] concurred.<ref name=":0" />


== Subsequent developments == == Subsequent developments ==
In 1996, 18 U.S.C. 1001 was amended to expressly include materiality as an element under each of the three clauses in subsection (a).<ref>{{Cite web |title=18 U.S. Code § 1001 - Statements or entries generally |url=https://www.law.cornell.edu/uscode/text/18/1001 |access-date=2024-12-26 |website=LII / Legal Information Institute |language=en}}</ref> In 1996, 18 U.S.C. 1001 was amended to expressly include materiality as an element under each of the three clauses in subsection (a).<ref>{{Cite web |title=18 U.S. Code § 1001 - Statements or entries generally |url=https://www.law.cornell.edu/uscode/text/18/1001 |access-date=2024-12-26 |website=LII / Legal Information Institute |language=en}}</ref>


Scholars noted Gaudin is unlikely limited to 18 U.S.C. § 1001 but may apply to any other offenses in which the materiality of a false statement is an element of the offense, such as making false statements to various financial institutions.<ref>{{Cite journal |last=Saks |first=Jeffrey |date=1995 |title=United States v. Gaudin: A Decision with Material Impact |url=https://ir.lawnet.fordham.edu/cgi/viewcontent.cgi?article=3227&context=flr |journal=] |volume=64 |issue=3}}</ref><ref>{{Cite web |title=CARES Act Fraud Enforcement & Materiality Concerns |url=https://natlawreview.com/article/materiality-concerns-cares-act-enforcement-cases |access-date=2024-12-26 |website=natlawreview.com |language=en}}</ref> Scholars noted ''Gaudin'' is unlikely limited to 18 U.S.C. § 1001 but may apply to any other offenses in which the materiality of a false statement is an element of the offense, such as making false statements to various financial institutions.<ref>{{Cite journal |last=Saks |first=Jeffrey |date=1995 |title=United States v. Gaudin: A Decision with Material Impact |url=https://ir.lawnet.fordham.edu/cgi/viewcontent.cgi?article=3227&context=flr |journal=] |volume=64 |issue=3}}</ref><ref>{{Cite web |title=CARES Act Fraud Enforcement & Materiality Concerns |url=https://natlawreview.com/article/materiality-concerns-cares-act-enforcement-cases |access-date=2024-12-26 |website=natlawreview.com |language=en}}</ref>
== See also ==

* ]

* ]


== References == == References ==
]
]
]
]
]
]
]
<references />{{US government sources}}

Latest revision as of 14:42, 28 December 2024

1995 United States Supreme Court case
United States v. Gaudin
Supreme Court of the United States
Argued April 17, 1995
Decided June 19, 1995
Full case nameUnited States v. Gaudin
Docket no.94-514
Citations515 U.S. 506 (more)115 S. Ct. 2310
ArgumentOral argument
Holding
The trial judge's refusal to submit the question of "materiality" to the jury was unconstitutional.
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinion
MajorityScalia, joined by unanimous
Laws applied
18 U.S.C. § 1001, U.S Constitution

United States v. Gaudin is a United States Supreme Court case in which the court held the trial judge's refusal to submit the question of "materiality" to the jury was unconstitutional. If materiality is a required element of the offense, it must be presented to the jury, which must determine it beyond a reasonable doubt for a conviction.

Background and procedural history

In the 1980s, Gaudin engaged in real estate transactions using FHA-insured loans from HUD. His scheme involved inflating property appraisals, selling properties to "straw buyers," and repurchasing them for profit. Many loans defaulted, and Gaudin was charged with making false statements under 18 U.S.C. § 1001.

At trial, the United States District Court for the District of Montana instructed the jury to determine whether Gaudin's statements were false, but decided itself the issue of materiality, a requirement for conviction under §1001, ruling materiality was not for the jury to consider. The jury convicted Gaudin.

Gaudi appealed. In 1993, the United States Court of Appeals for the Ninth Circuit reversed. On rehearing in 1994, the Court of Appeals held that taking the question of materiality from the jury violated the Fifth Amendment and Sixth Amendment of the U.S. Constitution.

Opinion of the court

In June 1995, Justice Scalia delivered the opinion of the Supreme Court and affirmed the judgment of the Court of Appeals.

Relying on the Fifth and Sixth Amendments, the Court held that the Constitution provisions "require criminal convictions to rest upon a jury determination that the defendant is guilty of every element of the crime with which he is charged, beyond a reasonable doubt." The trial judge's refusal to allow the jury to determine the materiality of Gaudin's false statements infringed that right.

Chief Justice Rehnquist, Justice O'Connor, and Justice Breyer concurred.

Subsequent developments

In 1996, 18 U.S.C. 1001 was amended to expressly include materiality as an element under each of the three clauses in subsection (a).

Scholars noted Gaudin is unlikely limited to 18 U.S.C. § 1001 but may apply to any other offenses in which the materiality of a false statement is an element of the offense, such as making false statements to various financial institutions.

See also

References

  1. ^ "United States v. Gaudin, 515 U.S. 506 (1995)". Justia Law. Retrieved 2024-12-26.
  2. ^ "United States of America, Plaintiff-appellee, v. Michael E. Gaudin, Defendant-appellant, 997 F.2d 1267 (9th Cir. 1993)". Justia Law. Retrieved 2024-12-26.
  3. "United States of America, Plaintiff-appellee, v. Michael E. Gaudin, Defendant-appellant, 28 F.3d 943 (9th Cir. 1994)". Justia Law. Retrieved 2024-12-26.
  4. "18 U.S. Code § 1001 - Statements or entries generally". LII / Legal Information Institute. Retrieved 2024-12-26.
  5. Saks, Jeffrey (1995). "United States v. Gaudin: A Decision with Material Impact". Fordham Law Review. 64 (3).
  6. "CARES Act Fraud Enforcement & Materiality Concerns". natlawreview.com. Retrieved 2024-12-26.

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