In the United States v. Yermian case of 1983, the Supreme Court ruled that a defendant could be convicted under 18 U.S.C. §1001 for making false statements to a federal agency even if they were unaware their statements would end up in the hands of such an agency. The defendant, Mr. Yermian, was charged with providing false information on security clearance forms while working for a private company contracted by the Department of Defense (DoD). He argued he did not know these forms would be sent to DoD and thus should not be held accountable under §1001 which criminalizes knowingly lying "in any matter within jurisdiction" of federal agencies. However, the court decided in favor of government's interpretation that only knowledge about falsity is required but not knowledge about federal involvement or jurisdiction.

In the dissenting opinion for United States v. Yermian, Justice O'Connor argued that the majority misinterpreted 18 U.S.C. Section 1001 by not requiring proof of a defendant's knowledge that their false statements would be used in a matter within federal jurisdiction. She contended that this interpretation was inconsistent with both the legislative intent and precedent set by prior court rulings which required such knowledge to establish guilt under similar statutes. The justice believed it was necessary to prove defendants knew they were making false statements in matters involving federal jurisdiction because without this requirement, individuals could unknowingly violate the law simply by lying about trivial matters during casual conversations with federal employees or contractors - an outcome she deemed absurd and unjust.