Federal 7th Circuit Court
Criminal Court
Jury Instructions
In prosecution on charge of exporting munitions illegally under 22 USC sections 2778(b)(2) and (c), Dist. Ct. erred in giving jury instruction on definition of “willfulness” that did not require jury to find that defendant knew that articles that he was actually exporting were on list of prohibited items for export. However, error was harmless where: (1) record overwhelmingly showed that defendant had exported certain part for military plane that he knew was embargoed; and (2) issue of defendant’s knowledge of illegality of his conduct was squarely placed with jury.