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Joseph Sullivan v. United States

Paid petition · United States Court of Appeals for the Ninth Circuit, No. 23-927 · judgment March 13, 2025


Certiorari denied · June 29, 2026
Pre-decision estimate: 1% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

In several cases over the last three decades, this Court has recognized that certain obstruction-of-justice crimes carry a “nexus requirement”—the requirement that a defendant’s conduct have the “natural and probable effect” of obstructing a proceeding and that the defendant know that his conduct will have that effect. The courts of appeals have adopted this requirement for a host of additional obstruction provisions, and trial courts routinely instruct juries that they must find a nexus to convict. The Second and Seventh Circuits have both recognized that 18 U.S.C. § 1505, which criminalizes obstruction of “a proceeding … before a [U.S.] department or agency,” carries the nexus requirement on which a jury must be properly instructed. But the Ninth Circuit holds that § 1505 carries no nexus requirement and it affirmed the conviction here despite no nexus instruction. The question presented is: Does 18 U.S.C. § 1505 carry the requirement, on which a jury must be instructed, that the defendant’s conduct have a nexus to an agency proceeding?

Counsel of record

For petitioner
Christopher Jason Cariello
Orrick, Herrington & Sutcliffe LLP

For respondent
D. John Sauer
Solicitor General

Case

Conference history
Distributed for 1 conference

Linked docket
25A853

Proceedings

  1. Jun 29 2026
    Petition DENIED.
  2. Jun 09 2026
    DISTRIBUTED for Conference of 6/25/2026.
  3. Jun 08 2026
    Reply of petitioner Joseph Sullivan filed. (Distributed)
  4. May 26 2026
    Brief of respondent United States in opposition filed.
  5. May 08 2026
    Motion to extend the time to file a response is granted and the time is extended to and including May 26, 2026.
  6. May 06 2026
    Motion to extend the time to file a response from May 15, 2026 to May 26, 2026, submitted to The Clerk.
  7. Apr 13 2026
    Motion to extend the time to file a response is granted and the time is extended to and including May 15, 2026.
  8. Apr 10 2026
    Motion to extend the time to file a response from April 15, 2026 to May 15, 2026, submitted to The Clerk.
  9. Mar 12 2026
    Petition for a writ of certiorari filed. (Response due April 15, 2026)
  10. Jan 30 2026
    Application (25A853) granted by Justice Kagan extending the time to file until March 12, 2026.
  11. Jan 23 2026
    Application (25A853) to extend the time to file a petition for a writ of certiorari from February 10, 2026 to March 12, 2026, submitted to Justice Kagan.