Waldemar Ratzlaf and Loretta Ratzlaf v. United States (510 U.S. 135)
U.S. Supreme Court · decided January 11, 1994 · Supreme Court Database (Spaeth)
- Citation
- 510 U.S. 135 · 114 S. Ct. 655
- Decided
- January 11, 1994
- Term
- October Term 1993
- Vote
- 5–4
- Majority author
- Justice Ginsburg
- Issue area
- Criminal Procedure
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice Ginsburg delivered the opinion of the Court. Federal law requires banks and other financial institutions to file reports with the Secretary of the Treasury whenever they are involved in a cash transaction that exceeds $10,000. 31 U. S. C. § 5313; 31 CFR § 103.22(a) (1993). It is illegal to “structure” transactions — i. e., to break up a single transaction above the reporting threshold into two or more separate transactions — for the purpose of evading a financial institution’s reporting requirement. 31 U. S. C. § 5324. “A person willfully violating” this antistructuring provision is subject to criminal penalties. §5322. This case presents a question on which Courts of Appeals have divided: Does a defendant’s purpose to circumvent a bank’s reporting obligation suffice to sustain a conviction for “willfully violating” the antistructuring provision? We hold that the “willfulness” requirement mandates something more. To establish that a defendant “willfully violated]” the antistructuring law, the Government must prove that the defendant acted with knowledge that his conduct was unlawful. I On the evening of October 20, 1988, defendant-petitioner Waldemar Ratzlaf ran up a debt of $160,000 playing blackjack at the High Sierra Casino in Reno, Nevada. The casino gave him one week to pay. On the due date, Ratzlaf returned to the casino with cash of $100,000 in hand. A casino…
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