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).
Janis rented a house to Orlando, who Janis should have known would use the house for his illegal gambling ring. Janis was prosecuted as an accomplice to the illegal gambling. The trial court gave the ostrich defense that "you may infer knowledge from a combination of suspicion and indifference to the truth".
The court of appeals writing (italics added for emphasis):