United States v. Gaudin

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.

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.

[1] 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.

[5][6] This article incorporates public domain material from websites or documents of the United States Government.