United States v. Rogers’s Empirical Analysis

Citation profile

30 federal appellate ·

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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “a criminal conviction for willfully violating Sec. 5324(3) may be sustained as long as the prosecution proves that the defendant had knowledge of the currency reporting requirements and acted to avoid them.”

   2 later decisions quote this exact passage · from the majority
   e.g. United States v. Todaro · United States v. Camille Todaro

2. “In Cheek, the rationale for the Court’s exception to the traditional interpretation of “willful” was the complexity of the tax code, which often makes it difficult for the average citizen to know what the law requires. Cheek [498 U.S. at -] 111 S.Ct. at 609-10 . That sort of complexity simply is not present in cases involving the “straightforward currency reporting requirements.” U.S. v. Dashney, 937 F.2d 532 at 540 (10th Cir.1991). Like the court in Dashney, we believe that the circumstances justifying an adoption of the Cheek definition of “willfulness” are limited, and this case does not present them.”

   1 later decision quote this exact passage · from the majority
   e.g. United States v. Beaumont

3. “This interpretation of “willful” [set forth by Judge Learned Hand in American Surety Co. v. Sullivan, supra] runs parallel to the rule that “ignorance of the law. is no excuse.” That rule is “deeply rooted' in the American legal system,” Cheek v. United States, 498 U.S. 192 [199] 111 S.Ct. 604, 609 , 112 L.Ed.2d 617 (1991), and exceptions to it must not be casually created.”

   1 later decision quote this exact passage · from the majority
   e.g. United States v. Obiechie