United States v. Johnson, No. 20-1449 (3d Cir. 2021)
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Johnson developed an obsession with the allegations of sexual assault against entertainer Bill Cosby. Hoping to discredit the accusers, Johnson posed as an attorney and filed a fabricated document on the civil docket of a lawsuit against Cosby. His trick was quickly discovered. Johnson was convicted of making a false statement and identity theft. On appeal, he argued that the prosecution failed to prove that his statements were material as necessary to establish liability under 18 U.S.C. 1001.
The Third Circuit reversed Johnson’s convictions. Johnson’s behavior wasted public time and resources and distracted court officials from their work but only Congress can define a federal crime. While there was significant evidence that Johnson’s statements were false, there was no evidence that any decision entrusted to the judge in the underlying Cosby trial could have been influenced by the praecipe filed by Johnson, which contained an unsigned exhibit that accused a party of failing to report income. This false statement, even if considered by the judge, was not relevant, much less material. Far from proving that using a false identity enabled the false praecipe to be filed, the record reveals that Johnson’s identity was immaterial and that Johnson could have filed the same documents under his, or any other, name.
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