United States v. McCaffrey

Michael McCaffrey (defendant) suffered from a neurological disorder that required him to sleep for all but four hours daily and that caused him to suffer from chronic depression. Nevertheless, McCaffrey was married and had three children, earned a college degree, and worked as a tax accountant for an accounting firm before starting his own solo practice in which he helped clients file their federal tax returns. McCaffrey also held a black belt in a martial art. McCaffrey and his wife, Sharon, did not file their tax returns for 1980 through 1992. In early 1994, just eight days after learning that the Internal Revenue Service was investigating him, McCaffrey filed his delinquent returns. In July 1996, McCaffrey was charged with four criminal counts of willfully failing to file his tax returns for 1989 through 1992. At a bench trial before a magistrate judge, McCaffrey called as an expert witness a doctor (who also was a friend) who testified that McCaffrey’s depression may have affected McCaffrey’s ability to file his taxes. Another doctor whom McCaffrey called as an expert witness testified about McCaffrey’s neurological condition but conceded that the condition did not prevent McCaffrey from filing his tax returns. The United States’ expert-witness doctor also testified that McCaffrey was capable of filing his tax returns. The magistrate judge found McCaffrey guilty and sentenced McCaffrey to prison, imposed a fine, and ordered McCaffrey to file his 1993–1996 returns. The district court affirmed. McCaffrey appealed, arguing that the United States failed to present sufficient evidence that McCaffrey willfully failed to file the relevant returns.