UNITED STATES v. PATE

No. 20-10545.

43 F.4th 1268 (2022)

UNITED STATES of America, Plaintiff-Appellee, v. Timothy Jermaine PATE, Defendant-Appellant.

United States Court of Appeals, Eleventh Circuit.

Filed: August 10, 2022.


Attorney(s) appearing for the Case

Nancy Greenwood , U.S. Attorney's Office, Augusta, GA, James C. Stuchell , U.S. Attorney Service — Southern District of Georgia, U.S. Attorney's Office, Savannah, GA, for Plaintiff-Appellee.

Justin Maines , The Nye Law Group, PC, Savannah, GA, for Defendant-Appellant.

Before Newsom, Branch, and Lagoa, Circuit Judges.


Title 18 U.S.C. § 1521 prohibits the filing of a false lien or encumbrance against the property of any officer or employee of the United States "on account of the performance of official duties." In 2018, Timothy Jermaine Pate filed various false liens against John Koskinen, the former Commissioner of the Internal Revenue...

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