State v. Steed
Annotate this CaseAfter a jury trial, Frank and Joan Steed, husband and wife, were each convicted of three counts of failure to file a proper tax return and one count of engaging in a pattern of unlawful activity. The failure-to-file statute requires proof that a defendant failed to file with one of three specific intents. The Steeds moved to arrest the judgment largely on the same grounds upon which they relied in a previously denied motion to dismiss. Specifically, the Steeds contended that the State failed to provide sufficient evidence of two of the three specific intent alternatives. Ultimately, the trial court submitted only the two contested intent alternatives to the jury and excluded the remaining intent alternative. The Supreme Court reversed the Steeds’ convictions, holding (1) the State presented insufficient evidence of the two contested intent alternatives; (2) because the court excluded the single supported intent alternative and submitted the two unsupported intent alternatives to the jury, there was insufficient evidence to support the verdicts; and (3) because the pattern counts were contingent on the failure-to-file convictions, the pattern counts, along with the failure-to-file convictions, must be reversed.
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