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Extraction Summary

7
People
3
Organizations
1
Locations
5
Events
1
Relationships
3
Quotes

Document Information

Type: Legal document
File Size: 688 KB
Summary

This document is a page from a legal filing, arguing for a 'categorical approach' to interpreting statutes of limitation, specifically §3283. It cites several Supreme Court precedents, most notably U.S. v. Noveck (1926), to support the argument that an extended statute of limitations for fraud-related offenses only applies when fraud is an essential element of the crime itself, not when it is merely alleged as 'mere surplusage' in an indictment for a different crime like perjury or tax evasion.

People (7)

Name Role Context
Davis Party in a legal case
Mentioned in the citation 'U.S. v. Davis, 139 S. Ct. 2319 (2019)'.
Kawashima Party in a legal case
Mentioned in the citation 'Kawashima, 565 U.S. at 483'.
Leocal Party in a legal case
Mentioned in the citation 'Leocal v. Ashcroft, 543 U.S. 1, 7 (2004)'.
Ashcroft Party in a legal case
Mentioned in the citation 'Leocal v. Ashcroft, 543 U.S. 1, 7 (2004)'.
Morgan Party in a legal case
Mentioned in the citation 'U.S. v. Morgan, 393 F.3d 192, 198 (D.C. Cir. 2004)'.
Noveck Party in a legal case
Mentioned in the citation 'U.S. v Noveck, 271 U.S. 201, 202-203, 204 (1926)' as the subject of a key Supreme Court ho...
Scharton Party in a legal case
Mentioned in the citation 'see also Scharton, 285 U.S. at 522 (same, with respect to tax evasion)'.

Organizations (3)

Name Type Context
Supreme Court government agency
Referenced multiple times as the authority on interpreting statutes of limitation using a categorical approach.
D.C. Cir. government agency
Mentioned in the citation for 'U.S. v. Morgan, 393 F.3d 192, 198 (D.C. Cir. 2004)'.
DOJ government agency
Appears in the footer identifier 'DOJ-OGR-00021107'.

Timeline (5 events)

1921-11-17
The Act of November 17, 1921 was passed, which was later codified at 26 U.S.C. § 6531.
United States
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1926
The case of U.S. v Noveck was decided, holding that an extended statute of limitations for fraud did not apply to perjury.
United States
U.S. Noveck
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2004
The case of Leocal v. Ashcroft was decided, interpreting 18 U.S.C. § 16(b).
United States
Leocal Ashcroft
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2004
The case of U.S. v. Morgan was decided by the D.C. Circuit, interpreting 18 U.S.C. § 3237(a).
United States
U.S. Morgan
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2019
The case of U.S. v. Davis was decided, interpreting 18 U.S.C. § 924(c)(3).
United States
U.S. Davis
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Locations (1)

Location Context
United States
Mentioned in the context of legal cases (U.S. v. Davis, etc.) and in the phrase 'defraud the United States'.

Relationships (1)

Leocal → adversarial (legal) → Ashcroft
Parties in the legal case 'Leocal v. Ashcroft'.

Key Quotes (3)

"offenses involving defrauding or attempting to defraud the United States"
Source
— internal revenue laws proviso (Describing the type of offenses for which the statute of limitations is extended from three to six years.)
DOJ-OGR-00021107.jpg
Quote #1
"defrauding or an attempt to defraud the United States is an ingredient under the statute defining the offense."
Source
— Supreme Court (in U.S. v Noveck) (The condition under which the extended statute of limitations for fraud applies.)
DOJ-OGR-00021107.jpg
Quote #2
"mere surplusage"
Source
— Supreme Court (in U.S. v Noveck) (Describing fraud allegations in an indictment for a crime where fraud is not a required element, such as perjury.)
DOJ-OGR-00021107.jpg
Quote #3

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