Ratzlaf v. United States

Summary

The Court, in an opinion by Justice Ginsburg joined by Justices Stevens, Scalia, Kennedy, and Souter, held that conviction for willfully structuring currency transactions under 31 U. S. C. §§ 5322(a) and 5324(3) requires proof that the defendant knew the structuring was unlawful, not merely that he knew of a bank's reporting obligation and intended to evade it. Because the jury instructions omitted that requirement, the Court reversed and remanded. Justice Blackmun dissented, joined by Chief Justice Rehnquist and Justices O'Connor and Thomas, arguing that knowledge of the reporting requirements and a purpose to evade them establish willfulness, and that the majority's additional requirement conflicts with the statutory text, legislative intent, and ordinary principles governing ignorance of the law.