United States v. Snider
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United States v. Snider, 502 F.2d 645 (1972) was a case before the United States Court of Appeals for the Fourth Circuit. It was a consolidation of two separate cases: the first was a conviction for violation of 26 U.S.C. §7205, which prohibits submitting fraudulent tax information to an employer. The second was a conviction for violation of 18 U.S.C. §401, which prohibits "misbehavior ... as to obstruct the administration of justice."
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United States v. Snider | |
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Court | United States Court of Appeals for the Fourth Circuit |
Full case name | United States of America, Appellee, v. Lyle B. Snider, Appellant. United States of America, Appellee, v. Lyle B. Snider, and Sue T. Snider, Appellants. |
Argued | January 10 1974 |
Decided | July 2 1974 |
Citation(s) | 502 F.2d 645, 1974 U.S. App. LEXIS 7824 |
Case history | |
Subsequent history | Rehearing denied, reported at 502 F.2d 645 at 665. |
Holding | |
(1) Refusing to rise when a judge entered or exited the room was insufficient for a contempt citation. (2) Reporting 3 billion dependents on a tax form was so clearly inaccurate that it could not be considered an attempt to defraud the federal government. | |
Court membership | |
Judge(s) sitting | Winter, Craven and Widener |
Case opinions | |
Majority | Craven (opinion), joined by Winter |
Dissent | Widener |
Laws applied | |
26 U.S.C. §7205 (fraudulent tax filing) 18 U.S.C. §401 (contempt of court) |
On appeal, the Fourth Circuit held that the tax form was so clearly incorrect that it could not be considered an actual attempt to defraud the federal government. Thus the specific intent to violate this law was absent, and so no conviction would stand. As to the contempt charges, the court found that the appellants' actions did not obstruct the administration of justice, and so they had not violated that statue either. The court specifically declined to address the appellants' First Amendment arguments.