United States v. Linda Kay Richardson

After a trial by jury, appellant Linda Kay Richardson was convicted under 18 U.S.C. § 1001 for making false statements to the Department of Labor in order to obtain disability benefits under the Federal Employees Compensation Act (“FECA”). Richardson challenges her conviction on the ground that section 1001, the general federal false-statement statute, is limited by 18 U.S.C. § 1920, a specific false-statement statute applicable exclusively to federal employees’ compensation affidavits, reports, or claims. Because we conclude that the scope of section 1001 is limited by section 1920, we…