Fields v. United States
1947 U.S. App. LEXIS 1860, 164 F.2d 97, 82 U.S. App. D.C. 354 (1947)
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Rule of Law:
Under the federal statute for contempt of Congress (2 U.S.C. § 192), a "willful" default occurs when a person deliberately and intentionally fails to produce subpoenaed documents, and does not require proof of an evil or bad purpose.
Facts:
- An individual, referred to as Appellant, and his business associates purchased a quantity of bronze wire screen from the War Assets Administration and resold it for a significant profit.
- On August 12, 1946, Appellant testified before a select House of Representatives committee investigating the disposition of surplus property.
- During his testimony, Appellant provided the committee with a file that contained a memorandum detailing the profit from the transaction and listing brokerage payments to 'Glenn A. Dies' and two entries for 'John Doe'.
- The committee issued a subpoena duces tecum compelling Appellant to produce all records related to these payments, particularly those that would identify 'John Doe'.
- After receiving extensions, Appellant appeared before the committee on August 14 and again on August 15, 1946, without the subpoenaed records.
- On his final appearance, Appellant testified that he had provided the committee with all the records he possessed concerning the transaction.
- At trial, the government produced at least three relevant documents that it alleged were available to the Appellant at the time of the committee hearing and were willfully withheld.
Procedural Posture:
- A grand jury indicted Appellant in the U.S. District Court for the District of Columbia on two counts of contempt of Congress under 2 U.S.C. § 192.
- At trial, the district court granted a motion for acquittal on the first count.
- A jury found Appellant guilty on the second count of the indictment.
- The district court entered a judgment of conviction and sentenced Appellant to three months of confinement and a $250 fine.
- Appellant appealed the conviction to the United States Court of Appeals for the District of Columbia Circuit.
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Issue:
Does the term 'willfully' in the federal statute punishing contempt of Congress require proof of an evil or bad purpose for a conviction?
Opinions:
Majority - Clark, Associate Justice
No. The term 'willfully' in the context of the contempt of Congress statute means only that the failure to act was deliberate and intentional, not that it was done with an evil or bad purpose. The statute's objective is to facilitate the gathering of information by congressional committees, a purpose that would be defeated if a witness could escape penalty by professing good intentions while deliberately withholding subpoenaed materials. Citing Townsend v. United States, the court affirmed that 'willful' generally means that the person charged with the duty knows what he is doing, not that he must suppose he is breaking the law. Therefore, the trial court's jury instruction that the reason or purpose for non-compliance is immaterial, as long as the refusal was deliberate and not accidental, was correct. Appellant's claim of 'good faith' for producing some documents does not negate the jury's factual finding that he deliberately withheld others.
Analysis:
This decision significantly clarifies the mens rea (mental state) required for a conviction under the contempt of Congress statute, establishing a lower culpability standard than in many other criminal contexts. By defining 'willfully' as merely 'deliberate and intentional' rather than requiring proof of a 'bad purpose,' the court strengthens the enforcement power of congressional investigations. This precedent makes it substantially easier for the government to secure convictions against witnesses who intentionally obstruct committee inquiries, as prosecutors are relieved of the burden of proving the defendant's specific motive or intent to break the law. Consequently, defenses based on 'good faith' or lack of malicious intent are rendered largely ineffective in such cases.
