United States v. Bernhard Deutch

An indictment charged that Deutch “unlawfully refused to answer” five specific questions put to him by a Committee of Congress.

The District Court dismissed the indictment as insufficient because it did not charge that the defendant willfully refused. The trial court concluded that since the recent decision in Quinn v. United States, 1955, 349 U.S. 155, 75 S.Ct. 668, 99 L.Ed. 964, the word “willfully” was required in the indictment to make out a charge under the statute.

2 U.S.C.A. § 192, 1 under which the indictment was drawn, provides:

“Every person who having been summoned as a witness by the…