The Court found the Jury Instruction on Willfulness was Erroneous but Affirmed on the Harmless Error Standard

Seventh Circuit Criminal Case Summaries: Jury Issues - Instructions

United States v. Dobek, No. 14-3073. Dobek was indicted for exporting munitions illegally and conspiracy. He challenged the district court’s jury instruction on willfulness. The Court of Appeals criticized the parties’ submissions on the definition of willfulness and interpreted willfully in 22 U.S.C. § 2778 to require knowledge by the defendant that he needed a license to export the munitions that he exported. The Court found that the instruction given was in error but was harmless because no reasonable jury would have acquitted Dobek.