Ratzlaf v. United States, 510 U.S. 135, 15 (1994)

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Cite as: 510 U. S. 135 (1994)

Opinion of the Court

criminal activity") (quoting McBoyle v. United States, 283 U. S. 25, 27 (1931) (Holmes, J.)).

We do not dishonor the venerable principle that ignorance

of the law generally is no defense to a criminal charge. See Cheek v. United States, 498 U. S. 192, 199 (1991); Barlow v. United States, 7 Pet. 404, 410-412 (1833) (Story, J.). In particular contexts, however, Congress may decree otherwise. That, we hold, is what Congress has done with respect to 31 U. S. C. § 5322(a) and the provisions it controls. To convict Ratzlaf of the crime with which he was charged, violation of 31 U. S. C. §§ 5322(a) and 5324(3), the jury had to find he knew the structuring in which he engaged was unlawful.19

Because the jury was not properly instructed in this regard, we reverse the judgment of the Ninth Circuit and remand this case for further proceedings consistent with this opinion.

It is so ordered.

19 The dissent asserts that our holding "largely nullifies the effect" of § 5324 by "mak[ing] prosecution for structuring difficult or impossible in most cases." See post, at 161, 162. Even under the dissent's reading of the statute, proof that the defendant knew of the bank's duty to report is required for conviction; we fail to see why proof that the defendant knew of his duty to refrain from structuring is so qualitatively different that it renders prosecution "impossible." A jury may, of course, find the requisite knowledge on defendant's part by drawing reasonable inferences from the evidence of defendant's conduct, see Spies v. United States, 317 U. S. 492, 499-500 (1943) (illustrating conduct that can support permissible inference of an "affirmative willful attempt" to evade a tax); United States v. Bank of New England, N. A., 821 F. 2d 844, 854 (CA1 1987) (willfulness "is usually established by drawing reasonable inferences from the available facts"), and the Government has not found it "impossible" to persuade a jury to make such inferences in prosecutions for willful violations of §§ 5313, 5314, or 5316. See, e. g., United States v. Dichne, 612 F. 2d 632, 636-638 (CA2 1979) (evidence that Government took "affirmative steps" to bring the reporting requirement to the defendant's attention by means of visual notices supports inference that defendant "willfully violated" § 5316).

149

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