## Facts

- Larry Wayne Rodgers was indicted under 18 U.S.C. § 1001 for knowingly and willfully making false statements in matters within the jurisdiction of a federal department or agency.
- Rodgers reported to the FBI that his wife had been kidnapped; the FBI determined she had left voluntarily.
- Rodgers reported to the United States Secret Service that his wife was involved in a plot to assassinate the President; after locating her, agents learned she left to get away from Rodgers.
- Rodgers conceded the statements were false and were intended to prompt federal investigative efforts to locate his wife.
- The district court dismissed the indictment, concluding the investigations were not “matters within the jurisdiction” of the agencies under § 1001.
- The Eighth Circuit affirmed, interpreting “jurisdiction” narrowly to mean only an agency’s power to make final or binding determinations.

## Issues

1. Whether “any matter within the jurisdiction of any department or agency of the United States” in 18 U.S.C. § 1001 includes false statements made during criminal investigations conducted by federal agencies such as the FBI and the Secret Service.
2. Whether “jurisdiction” in § 1001 is limited to situations where an agency has authority to make final or binding determinations.

## Decision

- The Supreme Court reversed and reinstated the indictment.
- The Court held that § 1001 encompasses false statements made to the FBI and the Secret Service in the course of authorized criminal investigations.
- The Court rejected the Eighth Circuit’s narrow interpretation of “jurisdiction” and found no basis in text or legislative history to exclude criminal investigations.
- The Court held the rule of lenity did not apply because the statutory language was not sufficiently ambiguous.
- Justice Stevens concurred in the statutory interpretation but dissented in part on fair-notice/retroactivity concerns.

## Legal Principles

- For § 1001, “jurisdiction” has a broad, nontechnical meaning, covering matters committed to an agency’s authority and differentiating authorized functions from matters peripheral to agency business.
- “Any matter” in § 1001 includes criminal investigations conducted by federal departments and agencies.
- § 1001 protects authorized governmental functions from deception; absent clear statutory limits, courts should not create categorical exclusions (such as for criminal investigations) based on policy concerns.
- The rule of lenity applies only where statutory text remains grievously ambiguous after ordinary interpretive tools; it does not justify narrowing § 1001 when Congress used broad, inclusive language.
- An agency need not possess ultimate decisionmaking power over the subject of an investigation for false statements to fall “within the jurisdiction” of that agency under § 1001.

## Conclusion

The Court held that 18 U.S.C. § 1001 reaches false statements made to federal investigators during authorized criminal investigations, construing “within the jurisdiction” broadly to cover the full range of an agency’s official functions rather than only actions involving final or binding determinations.


United States v. Rodgers, 466 U.S. 475 (1984)