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United States v. Gaudin

United States v. Gaudin
Supreme Court of the United States
Argued April 17, 1995 Decided June 19, 1995
Full case name	United States v. Gaudin
Docket no.	94-514
Citations	515 U.S. 506 (more)115 S. Ct. 2310
Argument	Oral 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
Majority	Scalia, 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 alone the issue of materiality, a requirement for conviction under §1001, ruling it 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 Appeal held that taking the question of materiality from the jury violated the Fifth and Sixth Amendments.

Opinion of the Court

Justice Scalia delivered the opinion of the 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 pass on 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.

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.