United States v. Linda Kay Richardson
Opinion
Opinion
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 reverse Richardson’s conviction.
I. FACTS
In October of 1979, Richardson suffered a strained right groin muscle while employed as a Special Agent with the Bureau of Alcohol, Tobacco, and Firearms. She applied for. disability compensation benefits, which are available to certain federal employees who are injured while performing their duties. See 5 U.S.C. §§ 8101 et seq. Richardson was declared to be temporarily totally disabled by the Department of Labor through its Office of Workers’ Compensation Programs (“OWCP”), and she began to receive benefits on April 13, 1980.