The statutory language in 18 U.S.C.S. § 1001 requiring that knowingly false statements be made in any matter within the jurisdiction of any department or agency of the United States is a jurisdictional requirement. Its primary purpose is to identify the factor that makes the false statement an appropriate subject for federal concern. Jurisdictional language need not contain the same culpability requirement as other elements of the offense. The existence of the fact that confers federal jurisdiction need not be one in the mind of the actor at the time he perpetrates the act made criminal by the federal statute.
Respondent made false statements about his employment history and criminal history on a Department of Defense security questionnaire. The form had the words "Department of Defense" on it and stated that false answers would subject the applicant to prosecution. After the false answers were discovered, respondent admitted the falsifications but argued that he did not know that the answers would be transmitted to the federal government. He was charged with violations of 18 U.S.C.S. § 1001. He argued that the government failed to prove that the false statements were made with actual knowledge of federal agency jurisdiction. The appellate court reversed, and petitioner United States sought review. The court reversed the appellate court and affirmed the conviction. The court found that the statute's plain language and the legislative history established that proof of actual knowledge of federal agency jurisdiction was not required.
Did the Congress intend the terms "knowingly and willfully" in § 1001 to modify the statute's jurisdictional language, thereby requiring the Government to prove that false statements were made with actual knowledge of federal agency jurisdiction?
There is no support in the legislative history for respondent's argument that the terms "knowingly and willfully" modify the phrase "in any matter within the jurisdiction of [a federal agency]." The terms "knowingly and willfully" appeared in the 1918 Act, but the phrase "in any matter within the jurisdiction of [a federal agency]" did not. It is clear, therefore, that in the 1918 Act the terms "knowingly and willfully" did not require proof of actual knowledge of federal involvement. Nor does the legislative history suggest that by adding the jurisdictional prerequisite to the current provision Congress intended to extend the scope of those two terms. The jurisdictional language was added to the current provision solely to limit the reach of the false-statements statute to matters of federal interest.