Ellis E. Neder, Jr. fraudulently obtained bank loans and, using that money, conducted schemes involving land development fraud. Neder faced several counts of federal, wire, bank, and mail frauds. He was also charged with falsifying his federal income tax return. The main issue of concerning this Supreme Court decision began while Neder’s case was at the district court. The prosecution instructed the jury that they did not need to consider whether or not Neder’s false information was effective in causing the harm that he did. The prosecution argued that this factor was immaterial to the conviction process.
According to the prosecution, whether or not Neder succeeded in defrauding people was aside the point. Neder and his lawyers argued that this was an important fact of materiality in order to properly obtain conviction. This raises questions regarding the fairness of a trial because neglecting to mention a pertinent fact to the jury may influence the outcome of the trial.
Errors, in criminal procedure, are common; yet, it must be proven upon appeal that the error did harm to one’s case. In all practicality, trials would take an unreasonable amount of time if all pertinent facts involving one’s case were considered. Besides, it is not humanly possible to cover all factors involved in a criminal case.
Court errors are almost inevitable. Therefore, the Court’s decision in Chapman v. California (19 created the doctrine of “harmless error.” The doctrine of harmless error states that the court must hold the belief beyond a reasonable doubt that the omission of a pertinent fact of a case did not influence the outcome of a criminal case.
The doctrine of “harmless error” was the central question involving Neder’s case. Prior to this case becoming a Supreme Court decision, all of the lower courts upheld the original conviction by claiming that the prosecution’s omission of such facts did, in fact, constitute a “harmless error.” The Supreme Court also upheld this decision, denying Neder’s petition as well.
The key basis for this Supreme Court decision is given that there is no question of Neder’s guilt given the other evidence against him. This omission was not enough to influence the case’s outcome. Therefore, the omission of such information is erroneous in principle but not influential on the outcome of the case.
The secondary question involving the circumstances of Neder v. US is materiality an important element in considering mail, wire, and bank fraud cases. All crimes have elements. Materiality refers to a piece of evidence that logically influences the consequences of a case. In criminal proceedings, the prosecution must factually proof material evidence as a prerequisite for conviction. In particular, the prosecution stated that Neder’s use of false information was not needed for conviction.
The Supreme Court’s decision on this matter was different than the preceding decisions of the lower courts. The Supreme Court stated that it is important for the prosecution to prove that lied in the commission of fraud. Lying is a material element of the crime. Materiality, therefore, applied to bank, mail, and wire fraud.
The breakdown of the decision was at 6-3. Then Chief Justice William Rehnquist gave the Majority opinion. Supporters of the majority opinion were Justices Stevens, O’Connor, Thomas, Kennedy, and Breyer. Ginsburg, Scalia, and Souter were the three dissenting justices. The dissenters argued that depriving the petitioner of the right to have the jury consider each element of the crime could never constitute a harmless error.