United States v. Giovanetti, 919 F.2d 1223 (7th Cir. 1990), is a criminal case that interpreted the jury instruction known as the ostrich instruction, that willful ignorance counted as knowledge where required for a guilty mind (mens rea) in complicity to commit a crime. The court held that willful ignorance required a positive act to avoid knowledge, otherwise it reduces the mens rea requirement of proving "knowledge" to merely proving "negligence" (should have known). Judge Richard Posner wrote the court's opinion, stating: