United States v. Brent Edington, 992 F.3d 554

In 2012 Edington applied for an FSA loan, listing many assets he did not own and submitting false documents and a false sworn statement; alleged overt acts occurred through mid‑2012.
The government charged Edington by felony information (filed June 3, 2019) with conspiracy to violate 18 U.S.C. § 1014 (pursuant to 18 U.S.C. § 371 and § 1014).
Edington initially pled guilty before a magistrate judge, but the district court rejected the magistrate’s recommendation citing statute‑of‑limitations concerns and potential gaps in the factual basis for the plea.
The district court later granted Edington’s motion to dismiss the information as time‑barred under the five‑year statute in 18 U.S.C. § 3282(a).
The government appealed; the Sixth Circuit held that 18 U.S.C. § 3293(1) plainly includes “a conspiracy to violate” § 1014 and therefore provides a ten‑year limitations period, reversed the dismissal, and remanded for further proceedings. The court declined to resolve factual‑basis issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 3293(1)’s 10‑year limitations period applies to a conspiracy to violate § 1014	§3293(1) expressly covers “a violation of, or a conspiracy to violate … section 1014,” so a 10‑year limit applies	General conspiracy statute §371 is usually subject to §3282(a)’s 5‑year limit	Held: §3293(1) applies to conspiracies to violate §1014; 10‑year limitations period governs
Whether the district court correctly dismissed under the 5‑year statute §3282(a)	N/A (government appealed dismissal)	District court applied §3282(a) and dismissed the information	Held: Reversed — dismissal was erroneous because §3293(1) controls
Whether Rabhan (N.D. Miss.) compelled application of 5‑year limit	Government: Rabhan involved aiding and abetting, not conspiracy, so it does not apply	District court relied on Rabhan to apply five‑year limit	Held: Rabhan is distinguishable (aiding/abetting vs. conspiracy); does not control here
Whether the Sixth Circuit should resolve plea factual‑basis issues on appeal	Government limited appeal to statute of limitations	Edington and district court raised factual‑basis concerns earlier	Held: Court declined to decide factual‑basis issues and remanded for further proceedings

Consumer Prod. Safety Comm’n v. GTE Sylvania, 447 U.S. 102 (plain‑language interpretation is starting point)
Hoffman v. Conn. Dept. of Income Maint., 492 U.S. 96 (statutory construction: give effect to every word)
United States v. Habig, 390 U.S. 222 (limitations construed in favor of repose but not to negate plain text)
United States v. Grenier, 513 F.3d 632 (6th Cir.) (de novo review of statute‑of‑limitations dismissal)
United States v. Jackson, 635 F.3d 205 (6th Cir.) (plain‑language interpretation controls)
United States v. Lash, 937 F.2d 1077 (6th Cir.) (§3282 generally applies to §371 conspiracies unless another statute applies)
United States v. Knipp, 963 F.2d 839 (6th Cir.) (applied §3293 ten‑year limit to conspiracy charge)
United States v. Raza, 876 F.3d 604 (4th Cir.) (recognized §3293 ten‑year application)
United States v. Heinz, 790 F.3d 365 (2d Cir.) (recognized §3293 ten‑year application)