Needham v. United States

SPARKS, Circuit Judge.

This appeal presents the question of the right of a party, convicted in a federal court of a violation of the federal laws, to file a bill of review in equity after he has served his sentence for the crime, to falsify and avoid the record of the conviction, upon a showing that one of the pieces of evidence relied upon by the Government to prove his guilt was subsequently declared by the Government to be untrue.

Appellant is an attorney who was convicted on March 30, 1934, along with certain other defendants, of using the mails to defraud. He was sentenced to one year’s…