United States v. Hildebrandt

Hildebrandt (defendant) was a Minnesota farmer. Hildebrandt failed to make the mortgage payments on his farm, and the state of Minnesota foreclosed. Hildebrandt sent Internal Revenue Service (IRS) Forms 1099 to the individuals whom he believed had conspired to take his farm from him. Forms 1099 are used to report non-wage compensation. Hildebrandt believed that the amount he lost was taxable income to the law-enforcement officers, judges, attorneys, and lenders who were involved in the foreclosure proceedings. Hildebrandt filed 1099 forms with the IRS twice, attaching them to summary cover sheets on which he claimed to have paid millions in non-wage compensation. On one sheet, Hildebrandt swore under penalties of perjury that the accompanying documents were true. Hildebrandt was indicted for knowingly and willfully making false statements to a government agency in violation of 18 U.S.C. § 1001. Hildebrandt testified at trial that he believed the forms he filed were not false, he had a legal duty to file the forms, and he expected the IRS to collect the taxes due on the income reported on the forms. The district court instructed the jury that to convict Hildebrandt, it had to find that he knowingly, voluntarily, and intentionally made or used a false document in submitting Forms 1099 to the IRS knowing that the forms contained a false statement. Hildebrandt was convicted and argued on appeal that the district court erred in refusing to instruct the jury that a subjective good-faith belief that one is not violating the law negates the willfulness element of section 1001.