Eghbal Saffarinia, aka Eddie Saffarinia v. United States
AdministrativeLaw Arbitration JusticiabilityDoctri
Whether a false statement or omission allegedly intended to obstruct routine procedures, such as ordinary-course agency review of annual disclosure forms, constitutes intent to obstruct 'proper administration of any matter' within the meaning of 18 U.S.C. § 1519
QUESTION PRESENTED Congress made it unlawful to knowingly make certain false statements or omissions with intent “to obstruct” bankruptcy cases, federal investigations, or—most important here—“proper administration” of federal “matter[s].” 18 U.S.C. $1519. The penalty can be as high as 20 years’ incarceration. Ibid. In Marinello v. United States, 584 U.S. 1 (2018), this Court addressed the meaning of the similar phrase, “obstruct * * * due administration,” in an obstruction statute relating to the Internal Revenue Code. It held that “due administration” does not include “routine administrative procedures” like review of annual tax returns. Jd. at 4. In the decision below, the court of appeals held that the phrase “proper administration” of “matter[s]” in §1519 does reach “routine” processes like ordinary-course review of annually submitted forms. The question presented is: Whether a false statement or omission allegedly intended to obstruct routine procedures, such as ordinarycourse agency review of annual disclosure forms, constitutes intent to obstruct “proper administration of any matter” within the meaning of 18 U.S.C. § 1519. (i)