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Cheek v. United States
Supreme Court of the United States (1991)
Plaintiff/Respondent: United States
Defendant/Petitioner: Cheek; the defendant was a professional pilot wo was charged with "wilfully" failing to pay his federal income tax. The defendant argued that he honestly believed that he did not have to pay his taxes because tax laws were unconstitutional. He also argued that he honestly believed that wages were not income included under the tax laws. The trial court and the Court of Appeals convicted Cheek on the grounds that his beliefs were objectively unreasonable.
Issue: 1. In order for the defendant to use his honest beliefs as defense, do these beliefs need to be objectively reasonable? 2. Can the defendant use his belief that tax laws are unconstitutional as a defense? 3. Can the defendant use the belief that wages are not income as a defense?
Holding: 1. No 2. No. 3. Yes
Key Facts: The fact that the law required "wilful" evasion of taxes helped the court to determine that the congress did not intend this law to be a strict liability law and mens rea was required in order for a person to be convicted under this law.
Legal Reasoning: The court ruled that honest beliefs of the defendant do not have to be objectively reasonable and as long as the defendant honestly does something without the guilty mind, he should be allowed to use his beliefs a defense. The court further held that the defendant in the current case was aware of the fact that he had to pay taxes and he, as a matter of fact, had paid his taxes in the past. His argument that tax laws are unconstitutional is not the innocent mistake which can be used as a defense. The defendant could have paid his taxes and could have challenged the constitunality of the tax laws in the court, but he did not do so. So the defendant's unconstitutional argument is not an innocent mistake and can not be used as a defense. But the court did hold that the defendant's belief that wages are not income can be introduced as defense and it is up to the jury to decide whether these beleifs are honest. The court remanded the case for further proceedings consistent with the decision of this court.