In Neder v. United States, 527 U.S. 1, 8-9, 144 L. Ed. 2d 35, 119 S. Ct. 1827 (1999), the Supreme Court held that a trial court's determination of materiality in a tax fraud case, which violated United States v. Gaudin, 515 U.S. 506, 132 L. Ed. 2d 444, 115 S. Ct. 2310 (1995) (holding that materiality is an element for the jury), was not a structural error that rendered the trial fundamentally unfair. Rather, the Court held that although the failure to submit the element to the jury violated the right to a jury trial, the error was subject to harmless error analysis. 527 U.S. at 9, 12. Thus, in the Supreme Court's view, a Sixth Amendment error does not automatically require a retrial even if a jury did not decide all the facts relevant to sentencing.