Haas v. Henkel
Citation and Court
216 U.S. 462 (1910), Supreme Court of the United States
Facts
Haas was charged with conspiracy to defraud the United States under what is now 18 U.S.C. § 371. The alleged conspiracy involved providing false crop reports to the Department of Agriculture, which were then used to manipulate commodity prices. No money belonging to the government was taken, and the government suffered no direct financial loss. Haas argued that the conspiracy statute required an intent to cheat the government out of property or money.
Issue
Whether the federal conspiracy-to-defraud statute reaches conspiracies to obstruct and impair the lawful functions of a government agency even when no money or property of the United States is sought or obtained.
Holding
The conspiracy-to-defraud statute covers conspiracies to impair, obstruct, and defeat the lawful functions of any department of government, not merely conspiracies to obtain government money or property by fraud.
Rule / Doctrine
Under 18 U.S.C. § 371 (then Rev. Stat. § 5440), “to defraud the United States” is construed broadly to include conspiracies to impair, obstruct, or defeat the lawful functions and operations of a government department or agency through deceit, dishonesty, or misrepresentation, even if no money or property is at stake. This is the “Klein conspiracy” or “defraud clause” of § 371, as distinct from the “offense clause” which covers conspiracies to commit specific federal offenses.
Significance
Haas v. Henkel is a foundational case establishing the breadth of the § 371 defraud clause, a doctrine that has been repeatedly reaffirmed and applied to a wide range of obstruction schemes — including cases involving false statements to federal agencies, interference with regulatory functions, and later obstruction of congressional proceedings. It is regularly taught in federal criminal law courses alongside United States v. Hammoud and Dennis v. United States.