United States v. Grant, No. 15-10962 (5th Cir. 2017)Annotate this Case
Defendant was charged with four counts of making false statements under penalty of perjury in a bankruptcy proceeding in violation of 18 U.S.C. 152(3), and convicted of Counts Two through Four. The court held that the indictment was not defective, and any prejudice introduced to the jury by the indictment's "used" language was harmless; the evidence was sufficient to support her convictions; and the district court did not err by applying USSG 2J1.3, the perjury guideline, to her offense where the gravaman of the charge was that defendant interfered with the bankruptcy court's administration of justice, not that she defrauded any creditors. Accordingly, the court affirmed the judgment.