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 admit to facts sufficient to confer jurisdiction. Railway Co. v. Ramsey, 22 Wall. 322 , 89 U.S. 322, 327 , 22 L.Ed. 823 (1874). By failing to respond to the divorce complaint, Price admitted the factual allegations in the complaint. See Taylor v. Johnson, 262 A.2d 803, 804 (D.C.App.1970) (“The effect of the entry of default is the admission of the truth of the well pleaded allegations of the complaint”). Because the divorce complaint served on Price explicitly states that Price “is a resident of the District of Columbia ... and has been such for more than six months preceding the…