In United States v. Easterday, appellant Jack Easterday, the owner of a nursery home chain, failed to convince the Ninth Circuit to overturn his criminal conviction for his repeated and willful failure to pay employee payroll taxes. Easterday claimed that he lacked the financial ability to comply with his tax obligations, therefore his behavior was not "willful" and thus not criminal. The Ninth Circuit disagreed. This case serves as a reminder that the failure to pay payroll taxes can lead to civil and criminal penalties.