Conviction For Document Falsification Affirmed

In US v. Fontenot, No. 08-12266, the Eleventh Circuit affirmed defendant's conviction for making a false entry in a document with the intent to impede an investigation within the jurisdiction of a U.S. agency, on the ground that it was not clear under current law that 18 U.S.C. section 1519 requires that the defendant know that the investigation will fall within the jurisdiction of the federal government, and thus the district court did not commit plain error.

As the court wrote:  "Wilton Fontenot appeals his conviction under 18 U.S.C. § 1519 for making a false entry in a document with the intent to impede an investigation within the jurisdiction of a United States agency. Fontenot claims that, to convict under § 1519, the Government must prove he knew the investigation would be a federal investigation. Finding this claim without merit under plain error review, we affirm Fontenot's conviction."

Related Resources

• Full Text of US v. Fontenot, No. 08-12266