United States v. Polychron’s Empirical Analysis
841 F.2d 833 · 1988
Citation profile
21 federal appellate · 11 district ·
How this case has been cited
Cited by 38 later decisions — most recently July 2018 · most notably United States v. American Investors of Pittsburgh, Inc. (1989), United States v. Jerkins (1989)
21 federal appellate · 11 district ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 18 U.S.C. § 1001 (Comprehensive Thrift and Bank Fraud Prosecution and Taxpayer Recovery Act of 1990) · 18 U.S.C. § 2 · 18 U.S.C. § 371 · 31 U.S.C. § 5313
Relies on Energy Cooperative, Inc. v. Phillips Petroleum Co. · Adman v. United States · United States v. Nersesian · Oklahoma Tax Commission v. Texas Co. · United States v. Anzalone
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Here, the defendant charged with violating the reporting laws is the president of the bank at which the currency transactions were made, in sharp contrast to a bank customer [as in Larson] acting without the bank’s knowledge. It is axiomatic that in our case the bank was alleged to be aware of the statutory duty to report as well as the deliberate efforts to evade that duty.... Accordingly, we hold that the Reporting Act sufficiently apprised Polychron that when a financial institution or its officer or employee acting within the scope of his employment structures an otherwise reportable transaction into multiple transactions in a single day that do not individually exceed $10,000, the bank or its officer or employee may be held criminally responsible for failing to file, or causing the bank to fail to file, a CTR.”
2 later decisions quote this exact passage · from the majority“(a) Whoever commits an offense against the United States or aids, abets, counsels, commands, induces or procures its commission, is punishable as a principal. (b) Whoever willfully causes an act to be done which if directly performed by him or another would be an offense against the United States, is punishable as a principal.”
2 later decisions quote this exact passage · from the majority“It [was] axiomatic that in [Polychron ] the bank was alleged to be aware of the statutory duty to report as well as the deliberate efforts to evade that duty_ Polychron’s alleged complicity in structuring the withdrawal of currency ... in an effort to avoid the reporting requirement is enough to differentiate this case from Larson and others dealing with the criminal liability of bank customers who structure currency transactions.... Poly-chron willfully caused [the bank] to fail to file the CTRs.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.