In Berra v. United States, the Supreme Court ruled in favor of the government, upholding a conviction for tax evasion against baseball player Joe Garagiola's brother-in-law, Dale W. Berra. The case revolved around whether or not it was necessary to prove that an individual knew they were breaking the law when committing tax fraud. In this instance, Berra had claimed deductions on his taxes for payments made as part of a kickback scheme with his employer; he argued that because he believed these payments to be legal and deductible business expenses at the time they were made, he should not be held liable for tax evasion. The court disagreed with this argument and upheld his conviction by stating that ignorance of law is no excuse (a principle known as "ignorantia juris non excusat"). It clarified further by saying even if someone genuinely believes their actions are lawful due to misunderstanding or misinterpretation of law doesn't make them immune from prosecution if those actions are indeed unlawful under existing laws.

In the dissenting opinion for Berra v. United States, Justice Hugo Black argued that the majority's decision was a departure from established legal principles and precedent. He contended that tax evasion and filing false returns are separate offenses, each requiring proof of different elements. Therefore, he believed they should not be considered as one crime under the Blockburger test which states that where two statutory provisions criminalize the same conduct under different names, only one punishment can be imposed. According to him, this case did not meet those criteria because each offense required proof of an element that other did not have: willfulness for tax evasion and falsity for filing false return. Thus in his view it was wrong to convict Berra on both charges since doing so would violate double jeopardy clause of Fifth Amendment which protects against multiple punishments for same offense.