510 U.S. 135, 114 S. Ct. 655, 126 L. Ed. 2d 615 (1994)
Waldemar Ratzlaf incurred a substantial gambling debt while playing blackjack at the High Sierra Casino in Reno, Nevada, in October 1988.1 The casino extended him one week to settle the $160,000 obligation.2 On the payment date, Ratzlaf returned with $100,000 in cash, prompting a casino official to explain the reporting requirements for cash transactions exceeding $10,000 and to recommend using a cashier's check.3 The casino arranged transportation and an escort to nearby banks for Ratzlaf.4
At the banks, Ratzlaf acquired several cashier's checks in amounts below $10,000 from different institutions to prevent the filing of currency transaction reports.5 He completed payment to the casino using these checks.6 The Ratzlafs engaged in additional similar transactions two months later, purchasing cashier's checks totaling $98,500 with cash and casino chips.7
Federal prosecutors charged Waldemar Ratzlaf and his wife Loretta with conspiracy and multiple counts of structuring currency transactions.8 Following a trial where the jury received instructions on the elements of the offense, the Ratzlafs were convicted on all counts.9 The Court of Appeals for the Ninth Circuit affirmed the convictions in 1992.10
The Supreme Court of the United States granted certiorari to consider the proper interpretation of the willfulness element in 31 U.S.C. § 5322(a).11
Whether a conviction for willfully violating the antistructuring provision requires the Government to prove that the defendant knew his structuring of currency transactions was unlawful?12
The term "willfully" in 31 U.S.C. § 5322(a) requires the Government to prove that the defendant knew the structuring of currency transactions was unlawful.13
Yes. The Court held that a willful violation of the antistructuring provision demands proof the defendant knew his conduct violated the law. The Ratzlafs purchased multiple cashier's checks below the $10,000 threshold at separate banks after learning of the reporting duty, yet the District Court instructed the jury solely on the purpose of evading reports without requiring knowledge of illegality.14 This omission of an essential element of the offense under §§ 5322(a) and 5324(3) necessitates reversal of the convictions affirmed by the Ninth Circuit.15
A conviction for willfully violating the antistructuring provision requires the Government to prove that the defendant knew his structuring of currency transactions was unlawful.16
Related opinions on this issue
Joined by The Chief Justice, Justice O'connor, And Justice Thomas
Justice Blackmun dissented.17 He contended that willfulness under § 5322(a) requires only knowledge of the financial institutions' reporting requirements together with a purpose to evade them.18 No additional proof that the defendant knew structuring itself was illegal is needed.19
The statutory text of § 5324 already supplies the requisite bad purpose by demanding an intent to evade reporting.20 This renders the majority's extra element inconsistent with precedent interpreting similar provisions and with the legislative history that sought to codify decisions such as United States v. Tobon-Builes.21 In his view, the majority's construction would largely nullify the antistructuring law by making most prosecutions impossible, contrary to Congress's clear aim to close the loophole that allowed easy circumvention of the Bank Secrecy Act.22