The United States v. Michael E. Gaudin case in 1994 revolved around the issue of whether or not a judge could determine the materiality of false statements made to federal agencies, which is a requirement for conviction under 18 U.S.C §1001. The defendant, Michael E. Gaudin, was charged with making false statements on Department of Housing and Urban Development forms while working as a loan broker. During his trial, the judge instructed the jury that they must accept as given that any falsehoods were "material," leaving them only to decide if such falsehoods had been knowingly made by Gaudin himself. Gaudin appealed this decision arguing it violated his Fifth and Sixth Amendment rights to have all elements of an offense proven beyond reasonable doubt before a jury; he believed jurors should also consider materiality rather than just accepting it from judges' instructions. The Supreme Court unanimously agreed with him stating that materiality was indeed an element required for conviction under §1001 and thus needed to be determined by juries rather than judges alone - thereby upholding defendants' constitutional right to have every element of their charges considered by peers.

In the dissenting opinion for United States v. Michael E. Gaudin, Justice Rehnquist argued that the majority's decision to require juries to determine materiality in false statement prosecutions was inconsistent with precedent and unnecessary. He pointed out that historically, courts have treated materiality as a question of law rather than fact because it requires a legal judgment about whether certain information is important enough to matter under the law. Furthermore, he contended that requiring juries to decide on materiality would not significantly enhance defendants' rights or improve verdict accuracy but would instead complicate trials and potentially confuse jurors by forcing them into complex legal determinations they are ill-equipped to handle.