United States v. Hildebrandt
United States Court of Appeals for the Eighth Circuit
961 F.2d 116 (1992)
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.
Rule of Law
Holding and Reasoning (Gibson, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 705,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 705,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 44,300 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.