18 U.S.C. § 1521
Retaliating against a Federal judge or Federal law enforcement officer by false claim or slander of title
Whoever files, attempts to file, or conspires to file, in any public record or in any private record which is generally available to the public, any false lien or encumbrance against the real or personal property of an individual described in section 1114, on account of the performance of official duties by that individual, knowing or having reason to know that such lien or encumbrance is false or contains any materially false, fictitious, or fraudulent statement or representation, shall be fined under this title or imprisoned for not more than 10 years, or both.
Notes of Decisions
Cited in 61
cases (20 in the last 5 years), 2006–2025 · leading case: United States v. Denard Neal, 776 F.3d 645 (9th Cir. 2015).
United States v. Denard Neal, 776 F.3d 645 (9th Cir. 2015). “SMITH, Circuit Judge: A defendant violates 18 U.S.C. § 1521 when the defendant files, attempts to file, *649 or conspires to file a false document of the sort regularly used to create liens or encumbrances against the real or personal property of a United States officer or…”
United States v. Tyrone Jordan, 851 F.3d 393 (5th Cir. 2017). “PER CURIAM: Tyrone Eugene Jordan appeals his conviction under 18 U.S.C. § 1521 for filing false liens or encumbrances.”
United States v. Timothy Jermaine Pate, 84 F.4th 1196 (11th Cir. 2023). “B A grand jury later indicted Pate on 21 counts—16 of them for filing false retaliatory liens against federal officials in violation of 18 U.S.C. § 1521 . The government’s case took three days, in- cluded 16 witnesses, and featured 136 exhibits.”
United States v. Reed, 668 F.3d 978 (8th Cir. 2012). “After a three-day trial, a jury convicted Davis and Reed of conspiring to file and filing false liens against Judge Hovland and Jordheim in violation of 18 U.S.C. § 1521 . The jury also convicted Reed of corruptly obstructing justice in violation of 18 U.”
United States v. Clarence Hoffert, 949 F.3d 782 (3rd Cir. 2020). “Cantil [Argued] Wei Xiang Office of United States Attorney 138 Delaware Avenue Buffalo, NY 14202 Counsel for Appellee ________________ OPINION ________________ SCIRICA, Circuit Judge Clarence Hoffert appeals his convictions and sentences under 18 U.S.C. § 1521 for filing false…”
United States v. Davila-Bonilla, 968 F.3d 1 (1st Cir. 2020). “Relevantly, he contested the 6-level enhancement on the ground that application note 2 of the commentary to § 2A6.”
United States v. Timothy Jermaine Pate, 43 F.4th 1268 (11th Cir. 2022). “” In 2018, Timothy Jermaine Pate filed various false liens against John Koskinen, the former Commissioner of the Internal Revenue Service, and Jacob Lew, the former Secretary of the Treasury.”
United States v. Williamson, 746 F.3d 987 (10th Cir. 2014). “a false lien and encumbrance against the real and personal property [of the IRS agents] on account of the performance of [their] official duties,” in violation of 18 U.S.C. § 1521 . Id. at 12-13 . Mrs. Williamson pleaded guilty to the second count *990 in return for dismissal of…”
Tobias Frank v. Derrick Schultz, 808 F.3d 762 (9th Cir. 2015). “The prison policy was based on a part of the Court Security Improvement Act, 18 U.S.C. § 1521 , which prohibits filing or attempting to file false liens against federal employees.”
United States v. Alphonso Wynn, 827 F.3d 778 (8th Cir. 2016). “§ 119 (b)(2)(A) (criminalizing publication of private information of “an individual designated in section 1114”); 18 U.S.C. § 1521 (criminalizing false claims “against the real or personal property of an individual described in section 1114”).”
Reginald Lundy v. John Yost, 405 F. App'x 690 (3rd Cir. 2011). “Lundy argued that the enactment of a federal criminal statute, 18 U.S.C. § 1521 , 1 criminalizing the filing or attempted filing in any public record of false lien claims against “any officer or employee of the United States or of any agency in any branch of the United States…”
United States v. Swallers, 897 F.3d 875 (7th Cir. 2018). “Soon after, the government charged Swallers with filing a false lien and encumbrance against a federal judge, in violation of 18 U.S.C. § 1521 , and with possessing ammunition as a felon, in violation of 18 U.”
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