United States v. Olson, No. 15-30022 (9th Cir. 2017)Annotate this Case
To secure a conviction for misprision of felony under 18 U.S.C. 4, the government must prove not only that the defendant knew the principal engaged in conduct that satisfies the essential elements of the underlying felony, but also that the defendant knew the conduct was a felony. In this case, defendant was convicted of misprision of felony based on her acts of concealing and failing to notify authorities of her business partner's submission of false statements to the USDA in connection with a federal grant application. The Ninth Circuit held that sufficient evidence supported the jury's finding that defendant had the requisite knowledge that her business partner's crime was punishable by more than a year in custody.