18 U.S.C. § 1021
Title records
Whoever, being an officer or other person authorized by any law of the United States to record a conveyance of real property or any other instrument which by such law may be recorded, knowingly certifies falsely that such conveyance or instrument has or has not been recorded, shall be fined under this title or imprisoned not more than five years, or both.
Notes of Decisions
Cited in 10
cases (8 in the last 5 years), 1973–2025 · leading case: Tam Anh Pham v. Deutsche Bank National Trust Co.
Tam Anh Pham v. Deutsche Bank National Trust Co. (2014)
“Next, the Phams’ assertions that the Defendants violated 18 U.S.C. § 1021 (2012) fail because there is no civil or private remedy for an alleged violation of this statute.”
United States v. Fred Lambert (1973)
“The analogous statute for perjury ( 18 U.S.C.A. § 1021 ) provides a maximum penalty of $2,000, five years imprisonment, or both.”
Williams v. Robison (2023)
“§ 1001 (False Statements to Government Officials) and 18 U.S.C. § 1021 (Falsification of Title Records).”
Viegas v. Kane (2024)
“§ 1341 , 18 U.S.C. § 1021 , and 15 U.S.C. § 1641 (g), and seek an order directing the Lender Defendants to “return all monies from the security instrument, extinguish the Deed of Trust from the property, and a Quiet Title shall be provided.”
Fitzgerald v. Wells Fargo & Company (2025)
“) Their complaint asserts four separate causes of action against Wells Fargo, all aimed at undermining the foreclosure action and avoiding enforcement of their mortgage. They allege claims for: (1) fraud in violation of Wis.”
Kaaihue v. State of Hawaii District Court Ewa Division (2022)
“1985) (“A case ‘arises under’ federal law only if the federal question 2 For example, Plaintiffs request “transfer” of the case to federal court pursuant to 18 U.S.C. §§ 1021 , 1028, 1036, 1091, 2340, 2340A, 2441, 2442 and 28 U.”
Viegas v. Kane (2024)
“5, 2015) (dismissing claim under 18 U.S.C. § 1021 because “the statute does not create a private right of action”); Saul v.”
Viegas v. LoanDepot Inc. (2024)
“§ 1641 (g), and a criminal statute, 18 U.S.C. § 1021 , because “[a] Chain of Title Analysis was performed by a licensed private investigator proving defendants had no claim to file a foreclosure action.”
Wells Fargo Bank NA v. Fitzgerald (2025)
“20 , Section 2-302 of the Uniform Commercial Code, and 18 U.S.C. §1021 , and that Wells Fargo wrongfully foreclosed on their home.”
Seyed Alireza Amidi Namin v. Kevin Jeffrey Vert (2025)
“§ 495 ; Claim Ten asserts “title records” under 18 U.S.C. § 1021 ; Claim Eleven asserts “major fraud against the United States” under 18 U.”
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