706
Opinion of the Court
1918, ch. 194, 40 Stat. 1015-1016 (1918 Act) (emphasis added).
The scope of this new provision is unclear. Although it could be read to create criminal liability for government-wide false statements, its principal purpose seems to have been to prohibit false statements made to defraud Government corporations, which flourished during World War I. Cf. Lebron v. National Railroad Passenger Corporation, 513 U. S. 374, 386-391 (1995) (tracing history of Government corporations). In one important respect, moreover, the statute remained relatively narrow: It was limited to false statements intended to bilk the Government out of money or property. See United States v. Cohn, 270 U. S. 339 (1926). Given the continuing focus on financial frauds against the Government, the 1918 Act did not alter the fundamental character of the original false claims statute.
The 1934 Act, which created the statute we now know as § 1001, did work such a change. Congress excised from the statute the references to financial frauds, thereby severing the historical link with the false claims portion of the statute, and inserted the requirement that the false statement be made "in any matter within the jurisdiction of any department or agency of the United States." This addition, critical for present purposes, is subject to two competing inferences. On one hand, it can be read to impose new words of limitation—whose ordinary meaning connotes the Executive Branch—in an altogether reformulated statute. On the other hand, it can be viewed as stripping away the financial fraud requirement while not disturbing the pre-existing breadth the statute had enjoyed from its association with the false claims statute.
The Bramblett Court embraced the latter inference, finding no indication in any legislative history that the amendment was intended to narrow the scope of the statute. We think this interpretation, though not completely implausible, is nevertheless unsound. The differences between the 1934
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