United States v. Price

MEMORANDUM *

Elizabeth A. Price appeals her jury conviction and sentence for perjury and for making false statements for use in determining rights to social security benefits, in violation of 18 U.S.C. § 1621 and 42 U.S.C. § 408(a)(3). We have jurisdiction pursuant to 28 U.S.C. § 1291, and we affirm.

I. Validity of District of Columbia Divorce Decree

Price is collaterally estopped from challenging the jurisdictional basis of her District of Columbia divorce decree in the context of this criminal proceeding. Although subject matter jurisdiction is generally not a waivable defense, the parties may…