Caseflicks

Court of Appeals for the D.C. Circuit • 1947

Fields v. United States

164 F.2d 97 | 82 U.S. App. D.C. 354 | 1947 U.S. App. LEXIS 1860

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Takeaway

In short, this case holds that contempt of Congress under § 192 requires an intentional failure to comply with a valid committee demand, not proof of an evil motive.

Background

Fields appeared before a House Select Committee investigating the disposal of surplus property after receiving a subpoena. The committee questioned him about a profitable resale of bronze wire screen purchased from the War Assets Administration. Fields voluntarily produced a file concerning the transaction, which contained a memorandum listing brokerage payments to Glenn A. Dies and two unidentified recipients designated as “John Doe.”

The committee issued a subpoena duces tecum directing Fields to bring records, checks, memoranda, and other evidence concerning those brokerage payments and the wire-screen sale. Fields received extensions and several opportunities to comply. At his final appearance, he maintained that he had provided every pertinent record in his possession. The Government later produced trial evidence that at least three responsive documents were available to him during the committee hearings.

A grand jury charged Fields with two counts of contempt of Congress under 2 U.S.C. § 192, one based on August 14 and one based on August 15, 1946. The district court acquitted him on the first count but submitted the second to the jury. The jury convicted, and the court imposed three months’ imprisonment and a $250 fine. Fields appealed.

Issues

Issue #1

Whether the evidence was sufficient to allow the jury to find that Fields willfully failed to produce records required by the committee’s subpoena.

Holding

Yes. The Government presented sufficient evidence for the jury to find that Fields deliberately withheld one or more subpoenaed documents within his control.

Reasoning

The subpoena specifically sought records identifying and documenting the brokerage payments reflected in Fields’s own memorandum, including checks, ledger sheets, memoranda, and other payment evidence. Fields was repeatedly given additional time to obtain and produce those materials, yet ultimately stated that he had supplied everything he possessed.

At trial, the Government introduced evidence of at least three documents pertinent to the transaction that were available to Fields when he appeared before the committee. That evidence permitted a reasonable jury to infer that Fields’s failure to produce the requested materials was deliberate rather than the product of mistake, inability, or accident.

Although Fields claimed he had turned over all responsive records, the conflict between that claim and the Government’s evidence presented a factual question for the jury. The appellate court would not displace the jury’s adverse resolution of that question.

Issue #2

Whether “willfully” in the congressional-contempt statute requires proof that the witness acted with an evil or bad purpose.

Holding

No. Under 2 U.S.C. § 192, a willful default is a deliberate and intentional failure to comply; the Government need not prove an evil or bad purpose.

Reasoning

The meaning of “willful” depends on the statute’s purpose and the nature of the prohibited conduct. The court rejected the proposition that the term always has a fixed criminal-law meaning requiring proof of an evil motive or knowledge that one is violating the law.

Congress enacted the contempt statute to make congressional investigations effective by compelling witnesses to appear, answer pertinent questions, and produce requested materials. Requiring proof of a bad or evil purpose would substantially weaken that objective by allowing a witness who intentionally withholds records to avoid liability merely by claiming a benign reason for doing so.

The trial court therefore correctly instructed the jury that the reason for Fields’s refusal was immaterial if his failure to comply was deliberate and intentional, rather than inadvertent or accidental. That interpretation followed the D.C. Circuit’s prior explanation that willfulness ordinarily means knowing what one is doing, not necessarily acting with a bad purpose.

Issue #3

Whether Fields’s voluntary production of some records required an instruction that his asserted good faith negated willfulness.

Holding

No. Partial voluntary production did not negate the issue whether Fields deliberately failed to produce additional subpoenaed documents under his control.

Reasoning

The alleged contempt was not based on Fields’s failure to produce every document at the outset. It was based on his alleged intentional withholding of particular records demanded by the subpoena after the committee had identified the information it needed and had afforded him repeated opportunities to provide it.

Evidence that Fields voluntarily supplied some documents did not resolve whether he deliberately withheld others. His asserted good faith therefore did not require the requested instruction, because the decisive factual question remained whether the missing responsive records were intentionally withheld.

The jury was properly allowed to decide that question from the evidence. Even if Fields’s possible motive was to protect his associate, a parolee whose conditions barred speculative activity, that motive could have been sympathetic rather than malicious and still would not excuse an intentional default.