In the United States v. Rodgers case of 1983, the Supreme Court ruled that a federal statute criminalizing false statements made to any department or agency of the U.S. government also applies to false statements made in jurisdictional matters before courts. The defendant, William Rodgers, was an attorney who had falsely represented himself as acting on behalf of another lawyer in order to gain access to his client's probation records from a court clerk's office. He was charged under Section 1001 of Title 18 which prohibits making fraudulent or false statements within the jurisdiction of any branch or department of the Federal Government. Rodgers argued that this law did not apply because he lied about his identity and purpose rather than lying about facts relevant to a matter being investigated by a government agency. However, Justice Byron White wrote for majority stating that Section 1001 covers all matters within its defined jurisdictions including those involving courts and their administration.

In the dissenting opinion for United States v. Rodgers, Justice Stevens argued that the majority's interpretation of 18 U.S.C §1001 was overly broad and could potentially criminalize a wide range of innocent conduct. He contended that this statute should only apply to false statements made with an intent to deceive federal agencies or officials in their performance of governmental functions, not those made during private disputes where no government interest is at stake. In this case, he believed Rodgers' false statement about having a law degree did not fall within the scope of §1001 as it was part of his personal dispute with his wife over custody rights rather than an attempt to mislead any federal agency or official. Furthermore, he pointed out that there were other more appropriate statutes under which Rodgers could have been prosecuted without stretching the meaning and application of §1001.