United States v. Yermian

Facts of the Case

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

Question

Does the government have to prove knowledge of federal agency jurisdiction in cases that deal with making false statements to a government department or agency?

CONCLUSION

No. Justice Lewis F. Powell delivered the opinion of the 5-4 majority. The Court held that the language of the statute applied the requirement of knowledge to the act of making false statements, rather than the jurisdiction. The Court also held that there was no legislative history to support the reading that Congress intended intent to deceive the federal government to be an element of the crime.In his dissenting opinion, Justice William H. Rehnquist wrote that there was a great deal of ambiguity in the statute regarding to which element the knowledge requirement applied. He argued that, without any clues in the statute, the majority’s opinion cannot simply decide what the phrase “knowingly and willfully” is meant to modify. He also argued that there was no evidence to suggest that Congress intended to expand the definition of the crime to any false statement that could fall under the jurisdiction of a federal agency. Justice William J. Brennan, Jr., Justice John Paul Stevens, and Justice Sandra Day O’Connor joined in the dissent.

Case Information

  • Citation: 468 US 63 (1984)
  • Argued: Mar 27, 1984
  • Decided Jun 27, 1984Granted: Nov 28, 1983