United States v. Stonehill

In order to commit fraud on the court, government misrepresentations in civil trials must be so substantial that they undermine the judicial process.

Stonehill and Brooks (“Taxpayers”) established successful businesses in the Philippines after World War II. U.S. and Philippine authorities were convinced that Taxpayers were violating tax laws of both countries. Philippine agents raided the businesses and recovered incriminating documents. Philippine authorities did not prosecute Taxpayers in part because the raid had violated their version of the 4th Amendment. Deported to the U.S, Taxpayers faced a civil suit filed by the government seeking back taxes. Taxpayers moved to suppress the documents, claiming U.S. agents unlawfully participated in the organization and execution of the raid. The district court found no U.S. participation and denied the motion. The Ninth Circuit affirmed on appeal. Over the next 30 years Taxpayers instigated more legal action to vacate the original order, but were unsuccessful. In August 2000, Taxpayers filed a new motion, accusing the government of committing fraud on the court in the original proceeding. The district court denied the motion, but the Ninth Circuit remanded the case back to allow Taxpayers to investigate newly uncovered evidence obtained through FOIA requests. The district court again denied the motion. On appeal, the Court held that the government had not committed fraud on the court because misrepresentations about U.S. involvement in the Philippines raid uncovered through the FOIA request were few, mostly tangential, and did not rise to the level of fraud. The judicial process was not compromised because both the district court and Ninth Circuit were able to properly analyze the case in the original action without the recently uncovered information. AFFIRMED.