Refusing to Submit Question of 'Materiality' to Jury When Defendant Charged With Making Material False Statements

In United States v. Gaudin, 515 U.S. 506, 132 L. Ed. 2d 444, 115 S. Ct. 2310 (1995), the Court was presented with the question of whether it is constitutional for the trial judge to refuse to submit the question of "materiality" to the jury where a defendant is criminally charged with making material false statements to a federal agency under 18 U.S.C. 1001. Gaudin, 515 U.S. 506, 132 L. Ed. 2d 444, 115 S. Ct. 2310. In analyzing the issue, the Court reaffirmed its previous holding that the Due Process Clause and the Sixth Amendment to the United States Constitution require criminal convictions to rest upon a jury determination that the defendant is guilty of every element of the crime with which the defendant is charged. Id. at 509-10. The Court then applied the well-settled law to the circumstance of a materiality finding necessary in the criminal false statement charge and held that the materiality of the alleged statement was an element of the offense; therefore, the jury had to determine whether the alleged statement was material in order to find the accused guilty. See Gaudin, 515 U.S. at 522-23.