Jones v. United States

Issue: Whether 18 U.S.C. § 514(a) — which prohibits the use of “any false or fictitious instrument, document, or other item appearing, representing, purporting, or contriving through scheme or artifice, to be an actual [government] security or other financial instrument” — prohibits only the use of nonexistent types of documents and instruments (as the U.S. Courts of Appeals for the 5th, 6th, 8th and 9th Circuits have held), or whether it also covers the use of fake versions of actual, existing types of documents and instruments (as the U.S. Courts of Appeals for the 11th and, in this case, 2nd Circuit have held).