Neder v. United States
United States Supreme Court
527 U.S. 1, 119 S. Ct. 1827 (1999)
- Written by Jamie Milne, JD
Facts
Ellis Neder (defendant) engaged in fraudulent real estate transactions. Neder was indicted in federal court on multiple counts of mail fraud, wire fraud, and bank fraud. He was also indicted on tax fraud for failing to report $5 million in income on his federal tax returns. The district-court judge erroneously instructed the jury that it need not consider the materiality of the tax returns’ false income statements. The judge also instructed the jury that materiality was not an element of mail or wire fraud. The jury convicted Neder of the fraud and tax offenses, and the court of appeals affirmed. The United States Supreme Court granted review to determine whether the erroneous tax instruction amounted to a structural error requiring reversal and whether materiality was an element of mail, wire, and bank fraud.
Rule of Law
Issue
Holding and Reasoning (Rehnquist, C.J.)
Dissent (Scalia, J.)
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