United States v. Murdock
1933 U.S. LEXIS 470, 54 S. Ct. 223, 290 US 389 (1934)
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Rule of Law:
In a federal criminal tax statute, the term 'willfully' requires the government to prove that a defendant acted with a bad purpose or evil motive to disobey the law, not merely that the act was voluntary. A defendant's good faith belief that their conduct was lawful is a defense, even if that belief was objectively unreasonable.
Facts:
- Murdock claimed deductions on his 1927 and 1928 federal income tax returns for money he had paid to other individuals.
- The Bureau of Internal Revenue summoned Murdock for an examination regarding these deductions.
- During the examination, a revenue agent questioned Murdock and asked for the names of the individuals who received the payments.
- Murdock refused to answer the questions or supply the requested information.
- Murdock stated that his refusal was based on his fear that the answers could incriminate him under state law.
- At the time of his refusal, the Supreme Court had not yet definitively ruled that the Fifth Amendment privilege against self-incrimination did not protect a witness in a federal proceeding from incrimination under state law.
Procedural Posture:
- The United States indicted Murdock in federal district court for willfully failing to supply information for his income tax returns.
- Murdock's special plea that he was protected by the Fifth Amendment was initially granted by the district court, but this decision was reversed by the Supreme Court in a prior appeal (United States v. Murdock, 284 U.S. 141) and the case was remanded.
- On remand to the district court, Murdock pleaded not guilty and was convicted by a jury.
- Murdock (as appellant) appealed his conviction to the U.S. Circuit Court of Appeals.
- The Circuit Court of Appeals reversed the district court's judgment of conviction.
- The United States (as petitioner) successfully petitioned the U.S. Supreme Court for a writ of certiorari to review the Circuit Court's decision.
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Issue:
Does the term 'willfully' in a federal criminal tax statute require proof of a bad purpose or evil motive, beyond a mere voluntary and intentional refusal to act?
Opinions:
Majority - Justice Roberts
Yes. The term 'willfully' in this criminal statute means more than a voluntary act; it implies an act done with a bad purpose or evil motive. The word, when used in a criminal context, generally means an act done without justifiable excuse, stubbornly, obstinately, or perversely. Congress included the willfulness requirement for failure to pay taxes, file returns, and keep records, indicating it did not intend to criminalize bona fide misunderstandings of complex tax law. Because the law regarding self-incrimination under state statutes was unsettled at the time, Murdock was entitled to a jury instruction that his good faith belief that he was entitled to refuse to answer should be considered in determining whether his refusal was willful.
Dissenting - Justice Stone and Justice Cardozo
No formal dissenting opinion was written, but Justice Stone and Justice Cardozo noted their opinion that the judgment of the Circuit Court of Appeals should be reversed.
Analysis:
This case establishes the 'good faith belief' defense in criminal tax law, defining 'willfulness' as the 'voluntary, intentional violation of a known legal duty.' The decision significantly raised the government's burden of proof by requiring it to prove a defendant's specific intent and bad purpose, not just a failure to comply with the law. This standard protects individuals who make honest mistakes or genuinely misunderstand complex regulations from facing criminal penalties, and it remains a cornerstone of tax law jurisprudence.
