In United States v. Rowland, a case decided on June 17, 2016, the U.S. Court of Appeals for the Second Circuit rejected a challenge by former Connecticut Governor John Rowland to his conviction on seven counts of violating campaign finance laws and falsifying records. In so doing, the panel issued an important decision regarding the interpretation of 18 U.S.C. §1519, a provision of the Sarbanes-Oxley Act, which prohibits the falsification of documents for the purpose of misleading government investigators. United States v. Rowland, No. 15-985 (2d Cir. June 17, 2016)
The Rowland decision tacks in a different direction from the U.S. Supreme Court’s recent decision in Yates v. United States, 135 S. Ct. 1074 (2015), in which the court narrowed the reach of this statute by adopting an interpretation rooted in the statute’s purpose. Rowland, by contrast, seems to take a broader approach. Given the tension between Rowland and Yates, and the Supreme Court’s longstanding interest in limiting the breadth of the statutes that prohibit obstruction of justice, Rowland may warrant further appellate review.
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