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Standefer v. United States

United States Supreme Court
447 U.S. 10 (1980)


Facts

In February 1977, Cyril Niederberger, an Internal Revenue Service agent overseeing Gulf Oil Corporation’s tax audits, was charged with 10 counts of accepting improper payments from Gulf in the form of five vacations. Niederberger was convicted of six counts but acquitted on four counts of accepting payments from Gulf for three of the trips. Following Niederberger’s trial, the United States government (plaintiff) charged Standefer (defendant), head of Gulf’s tax department, with five counts of aiding and abetting Niederberger in accepting illegal compensation. Standefer moved to dismiss the aiding-and-abetting charges related to the three vacations, contending that he could not be convicted of aiding and abetting crimes of which Niederberger, the principal perpetrator, had been acquitted. Standefer further argued that the doctrine of nonmutual collateral estoppel barred the government from relitigating Niederberger’s guilt in order to determine whether Standefer aided and abetted Niederberger’s crimes. The district court denied the motion. Standefer appealed. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Burger, C.J.)

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