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Neder v. United States

United States Supreme Court

527 U.S. 1 (1999)

Facts

A federal court tried Ellis Neder (defendant) for tax fraud based on his failure to report loan proceeds as income on tax returns. The judge improperly instructed the jury that it did not have to consider the materiality of the false statements on the returns to convict, reasoning that materiality “is not a question for the jury to decide.” Neder appealed to the United States Supreme Court, arguing that the erroneous instruction amounted to a structural error requiring reversal, regardless of whether the error was harmless.

Rule of Law

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Issue

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Holding and Reasoning (Rehnquist, C.J.)

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Dissent (Scalia, J.)

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