mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00021108.json

{
  "document_metadata": {
    "page_number": "61",
    "document_number": "59",
    "date": "02/28/2023",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 59, 02/28/2023, 3475902, Page61 of 113\n\nSimilarly, in Bridges v. U.S., 346 U.S. 209 (1953), the Court applied a categorical approach to the Wartime Suspension of Limitations Act (WSLA), which provided, in pertinent part, that \"[w]hen the United States is at war the running of any statute of limitations applicable to any offense ... involving fraud or attempted fraud against the United States ... shall be suspended....\" Act of June 25, 1948, c. 546, 62 Stat. 828 (emphasis added) (codified in its present version at 18 U.S.C. § 3287). The Government charged Bridges with willfully making a false statement, to wit, denying membership in the Communist Party, in connection with his 1945 naturalization application. Invoking the WSLA, the Government argued that the charges were timely. But the Supreme Court, recalling Noveck and Scharton, held that the WSLA was \"limited strictly to offenses in which defrauding or attempting to defraud the United States is an essential ingredient of the offense charged.\" Id. at 221 (emphasis added).\n\nIn this case, the court made no attempt to distinguish Scharton or Noveck. And though it purported to distinguish Bridges, it blatantly mischaracterized the Supreme Court's opinion, asserting that Bridges applied a categorical approach \"in large part\" because of the WSLA's legislative history. A149. The District Court's statement was wrong. Bridges' passing reference to legislative history concerned a different issue: whether the kind of \"fraud\" contemplated by the WSLA had to be fraud \"of a pecuniary nature.\" 346 U.S. at 216. But the Court then stated, as an\n\n46\n\nDOJ-OGR-00021108",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 59, 02/28/2023, 3475902, Page61 of 113",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Similarly, in Bridges v. U.S., 346 U.S. 209 (1953), the Court applied a categorical approach to the Wartime Suspension of Limitations Act (WSLA), which provided, in pertinent part, that \"[w]hen the United States is at war the running of any statute of limitations applicable to any offense ... involving fraud or attempted fraud against the United States ... shall be suspended....\" Act of June 25, 1948, c. 546, 62 Stat. 828 (emphasis added) (codified in its present version at 18 U.S.C. § 3287). The Government charged Bridges with willfully making a false statement, to wit, denying membership in the Communist Party, in connection with his 1945 naturalization application. Invoking the WSLA, the Government argued that the charges were timely. But the Supreme Court, recalling Noveck and Scharton, held that the WSLA was \"limited strictly to offenses in which defrauding or attempting to defraud the United States is an essential ingredient of the offense charged.\" Id. at 221 (emphasis added).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In this case, the court made no attempt to distinguish Scharton or Noveck. And though it purported to distinguish Bridges, it blatantly mischaracterized the Supreme Court's opinion, asserting that Bridges applied a categorical approach \"in large part\" because of the WSLA's legislative history. A149. The District Court's statement was wrong. Bridges' passing reference to legislative history concerned a different issue: whether the kind of \"fraud\" contemplated by the WSLA had to be fraud \"of a pecuniary nature.\" 346 U.S. at 216. But the Court then stated, as an",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "46",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021108",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Bridges"
    ],
    "organizations": [
      "U.S. Supreme Court",
      "Communist Party",
      "District Court"
    ],
    "locations": [
      "United States"
    ],
    "dates": [
      "02/28/2023",
      "1953",
      "June 25, 1948",
      "1945"
    ],
    "reference_numbers": [
      "22-1426",
      "59",
      "3475902",
      "61",
      "113",
      "346 U.S. 209",
      "18 U.S.C. § 3287",
      "62 Stat. 828",
      "A149",
      "DOJ-OGR-00021108"
    ]
  },
  "additional_notes": "The document appears to be a court document, likely a brief or memorandum, discussing the Wartime Suspension of Limitations Act (WSLA) and its application to a specific case. The text is printed and there are no visible stamps or handwritten notes. The document is paginated, with this page being page 61 of 113."
}