United States v. Vreeland, No. 10-1034 (6th Cir. 2012)
Annotate this CaseConvicted of conspiracy to defraud the U.S. in a check cashing scheme, Vreeland was sentenced to imprisonment, supervised release, and restitution. While on supervised release, he committed a home invasion and larceny. Co-defendant Russell later testified as to Vreeland’s role, disposal of stolen items and the getaway vehicle and their agreement to deny knowing each other. Vreeland informed Probation Officer Bobo that he and Russell were suspects in the case, but denied knowing Russell and stated that his vehicle had been sold to a junk yard. Officer Bobo requested documentation regarding the car, but Vreeland did not comply and was arrested for a supervised release violation and placed in a halfway house. Bobo began his own investigation and concluded that Vreeland had violated supervised release by committing the home invasion. Vreeland signed a written statement that he did not know Russell. Vreeland’s release was revoked when he was convicted of two counts of making false oral and written statements to a probation officer, 18 U.S.C. 1001(a)(2) (a)(3). The Sixth Circuit affirmed. False statements during monthly supervisory meetings are not protected by the Fifth Amendment privilege against self-incrimination, and do not fall within the “judicial function exception” to prosecution of 18 U.S.C. 1001(b).
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