United States v. White Eagle
United States Court of Appeals for the Ninth Circuit
721 F.3d 1108 (2013)
- Written by Sharon Feldman, JD
Facts
The Bureau of Indian Affairs (BIA) was the federal government’s trustee for tribal lands in Montana. White Eagle (defendant) was the BIA’s superintendent for the Fort Peck Reservation (the reservation). White Eagle was responsible for signing documents for loans that the reservation’s credit program made to tribal members. White Eagle supervised an employee who was engaged in a fraudulent scheme whereby credit-program employees obtained loans by filing applications in the name of nominee relatives and then splitting the proceeds among themselves. When the employee died, White Eagle told the employee’s husband that the employee, rather than nominee borrowers, had outstanding loans, and the employee’s husband paid the loans with money from the employee’s life insurance. White Eagle did not disclose that her employee had taken loans in the names of nominees. White Eagle was charged with concealing public corruption in violation of 18 U.S.C. § 1001(a)(1), the false-statements statute. On appeal, White Eagle argued that she did not have a duty to report the employee’s fraud.
Rule of Law
Issue
Holding and Reasoning (McKeown, J.)
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