Neder v. United States, 527 U.S. 1 (1999)

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CASES ADJUDGED

IN THE

SUPREME COURT OF THE UNITED STATES

AT

OCTOBER TERM, 1998

NEDER v. UNITED STATES

certiorari to the united states court of appeals for the eleventh circuit

No. 97-1985. Argued February 23, 1999—Decided June 10, 1999

Petitioner Neder was convicted of filing false federal income tax returns and of federal mail fraud, wire fraud, and bank fraud. At trial, the District Court determined that materiality with regard to the tax and bank fraud charges was not a question for the jury and found that the evidence established that element. The court did not include materiality as an element of either the mail fraud or wire fraud charges. The Eleventh Circuit affirmed. It held that the District Court's failure to submit the materiality element of the tax offense to the jury was error under United States v. Gaudin, 515 U. S. 506, but that the error was subject to harmless-error analysis and was harmless because materiality was not in dispute and thus the error did not contribute to the verdict. The court also held that materiality is not an element of a "scheme or artifice to defraud" under the mail fraud, wire fraud, and bank fraud statutes, 18 U. S. C. 1341, 1343, 1344, and thus the District Court did not err in failing to submit materiality to the jury.

Held:

1. The harmless-error rule of Chapman v. California, 386 U. S. 18, applies to a jury instruction that omits an element of an offense. Pp. 7-20.

(a) A limited class of fundamental constitutional errors is so intrinsically harmful as to require automatic reversal without regard to their effect on a trial's outcome. Such errors infect the entire trial process and necessarily render a trial fundamentally unfair. For all other con-1

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