United States v. Morse Erskine

In a trial to the court, appellant was convicted of violating 18 U.S.C. § 1014 , which prohibits “knowingly mak[ing] any false statement or report ... for the purpose of influencing in any way” the action of a federally insured bank. He does not challenge the sufficiency of the evidence, but appeals on the ground that the trial court should have allowed his medical doctor to testify that he lacked the mental capacity to form the specific intent to influence a bank.

The elements of a section 1014 violation include these requisite mental states: knowledge of falsity, and the intent to influence action by the financial institution concerning a loan or one of the other transactions listed in the statute. See United States v. Sabatino, 485 F.2d 540 (2d Cir. 1973), cert. denied, 415 U.S. 948 , 94 S.Ct. 1469 , 39 L.Ed.2d 563 (1974). The rule that a defendant may rebut or seek to disprove the Government’s case by showing that one or more elements of a criminal offense did not occur extends to any of the mental components necessary to establish guilt of the crime in question. The defendant here should be permitted to show at trial that he did not know the information he gave to the bank…