United States v. Rodgers
466 U.S. 475, 80 L. Ed. 2d 492, 1984 U.S. LEXIS 72 (1984)
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Rule of Law:
The phrase "within the jurisdiction" in 18 U.S.C. § 1001 is to be interpreted broadly, encompassing all matters confided to a federal department or agency's authority, including criminal investigations, regardless of whether the agency has the power to make final, binding adjudications.
Facts:
- On June 2, 1982, Larry Rodgers telephoned the Kansas City office of the FBI and falsely reported that his wife had been kidnaped.
- The FBI expended over 100 agent hours investigating the report before determining that Rodgers' wife had left him voluntarily.
- Two weeks later, Rodgers contacted the Kansas City office of the Secret Service.
- Rodgers falsely reported to the Secret Service that his wife was involved in a plot to assassinate the President.
- The Secret Service spent over 150 hours investigating this threat.
- Rodgers later confessed that he fabricated both reports to induce the federal agencies to locate his estranged wife.
Procedural Posture:
- Larry Rodgers was charged in a two-count indictment in the U.S. District Court for the Western District of Missouri.
- Rodgers moved to dismiss the indictment, arguing that the agencies' investigations were not matters 'within the jurisdiction' under the statute.
- The District Court granted Rodgers' motion to dismiss.
- The United States (appellant) appealed to the U.S. Court of Appeals for the Eighth Circuit.
- The Court of Appeals affirmed the district court's dismissal of the indictment against Rodgers (appellee).
- The United States petitioned the U.S. Supreme Court for a writ of certiorari, which was granted to resolve a conflict among the circuit courts.
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Issue:
Does the phrase 'within the jurisdiction of any department or agency of the United States' under 18 U.S.C. § 1001 apply to criminal investigations conducted by the FBI and the Secret Service, agencies which have the authority to investigate but not to make final binding determinations?
Opinions:
Majority - Justice Rehnquist
Yes. The phrase 'within the jurisdiction' under 18 U.S.C. § 1001 broadly covers matters within a federal agency's power to investigate, not just its power to make final binding determinations. The Court reasoned that the plain language of § 1001, which applies to 'any matter' within the jurisdiction of 'any department or agency,' suggests a sweeping scope. The ordinary, non-technical meaning of 'jurisdiction' is a sphere of authority, which includes the power to conduct an investigation based on information received. The Court found that a narrow interpretation, limiting the statute to agencies with adjudicative or regulatory power, would conflict with the statute's broad text and frustrate the legislative intent to protect the authorized functions of all governmental agencies from perversion by false statements. Precedent, such as Bryson v. United States, has consistently held that 'the term ‘jurisdiction’ should not be given a narrow or technical meaning for purposes of § 1001.' Since the FBI and Secret Service have a clear statutory basis for investigating kidnappings and threats to the President, respectively, Rodgers' false statements fell 'within the jurisdiction' of those agencies.
Analysis:
This decision resolves a circuit split and firmly establishes a broad interpretation of 'jurisdiction' for the purposes of 18 U.S.C. § 1001. By rejecting the narrow view that jurisdiction requires adjudicatory or final decision-making power, the Court ensures the statute can be used to prosecute individuals who lie to federal investigators, thereby protecting agency resources and the integrity of the investigative process. This precedent significantly strengthens the government's ability to deter and punish the submission of false information that triggers wasteful or malicious investigations across a wide range of federal agencies, not just those with regulatory or administrative functions.
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