United States v. Rodgers - 466 U.S. 475, 104 S. Ct. 1942 (1984)

Rule:

The term "jurisdiction" should not be given a narrow or technical meaning for purposes of 18 U.S.C.S. § 1001.

Facts:

An individual who confessed that he made false reports to the Federal Bureau of Investigation (FBI) that his wife had been kidnapped, and also to the United States Secret Service that his wife was involved in a plot to kill the President, was charged in a two-count indictment with making false statements to the FBI and the Secret Service in violation of 18 USCS 1001, which made it a crime to knowingly and willfully make a false statement "in any matter within the jurisdiction of any department or agency of the United States." The accused moved to dismiss the indictment on the grounds that the investigations conducted by the FBI and the Secret Service in connection with his false reports were not matters "within the jurisdiction" of the respective agencies, as that phrase is used in 1001. The District Court for the Western District of Missouri granted the motion, and the United States Court of Appeals for the Eighth Circuit affirmed, adhering to its decision in a prior case that the phrase "within the jurisdiction" referred only to the "power to make final or binding determinations." The government sought review of the decision.

Issue:

Was the issue “within the jurisdiction” of the FBI and the Secret Service, making it fall within the ambit of 18 USCS 1001?

Answer:

Yes.

Conclusion:

The Court reversed the decision of the lower courts, holding that the most natural, nontechnical reading of the statutory language was that it covered all matters confided to the authority of an agency or department. According to the Court, the phrase "within the jurisdiction" merely differentiated the official, authorized functions of an agency or department from matters peripheral to the business of that body. The Court averred that the term "jurisdiction" should not have been given a narrow or technical meaning. There existed a statutory basis for the authority of the FBI and the Secret Service over the investigations sparked by respondent. The critical statutory language of § 1001 was not sufficiently ambiguous to permit the rule of lenity to be controlling.