United States v. Wells

Summary

The Supreme Court held that materiality of a falsehood is not an element of the offense of knowingly making a false statement to a federally insured bank under 18 U.S.C. § 1014, reasoning from the statute's text, the 1948 consolidation history in which express materiality requirements were dropped from predecessor provisions, and Kay v. United States. It further held that Rule 30 and the law-of-the-case and invited-error doctrines did not bar the Government from taking that position despite having requested jury instructions treating materiality as an element, and it declined to resolve respondents' two newly raised objections (potential jury confusion from the materiality instruction and a claimed Fifth Amendment indictment problem), leaving them to the Court of Appeals. The Court vacated the Eighth Circuit's judgment, which had vacated the convictions and ordered a new trial, and remanded for further proceedings. Justice Stevens dissented, contending that § 1014 implicitly incorporates a materiality requirement and that the majority's reading would criminalize mere flattery of bank officers.