In the case of United States v. Therese A. Burke, Cynthia R. Center, and Linda G. Gibbs (1991), the defendants were charged with conspiracy to defraud the United States by obstructing functions of federal agencies including IRS and FDA, mail fraud, wire fraud and making false statements to a government agency in relation to their operation of an unlicensed blood plasma center which sold contaminated blood products overseas without proper testing for diseases such as Hepatitis B & C or HIV/AIDS. The Supreme Court ruled against them on all counts except one - obstruction of justice charge was dropped due to lack of evidence that they had knowingly lied about their activities during investigations by federal agents.

The dissenting opinion in the case of United States v. Therese A. Burke, Cynthia R. Center, and Linda G. Gibbs argued that the majority's decision to uphold convictions for conspiracy to defraud the United States was flawed due to a lack of evidence proving intent or knowledge on part of defendants about their actions being illegal under federal law. The dissenting justices contended that while there may have been some irregularities in how funds were handled by these individuals, it did not necessarily constitute a criminal act as per the statute they were charged under - 18 U.S.C §371- which requires proof beyond reasonable doubt that defendants had specific intent to violate federal law or deceive government officials knowingly and willfully with fraudulent claims or statements.