Employee Filing False Timesheets With Employer Under NSA Contract Within Scope of 1001

US v. Jackson: Jackson worked for Northrop Grumman, a sub-contractor on a "time-and-materials" contract with the NSA. During his employment, Jackson submitted false timesheets to his employer. He was charged with 20 counts of making false statements under 18 USC 1001. He moved to dismiss, arguing that his statements were not made "in relation to a matter within the jurisdiction of the executive branch." The district court denied the motion and Jackson entered a conditional guilty plea to three counts.

On appeal, the Fourth Circuit affirmed the denial of the motion to dismiss. On appeal, Jackson argued that because the NSA was created by executive order rather than a statute it had "no statutory basis" to access his timesheets. Noting that the "authority to safeguard federal funds" is "an official, authorized function of the executive branch," the court held that authority was, in itself, a sufficient jurisdictional nexus to bring the case within the reach of 1001. However, the court also noted that the NSA had an additional power when it came to Jackson - it could revoke his security clearance and terminate the contract under which her worked - that strengthened the nexus.