Timothy Pate filed retaliatory liens against the property of former IRS Commissioner Douglas Shulman, former IRS Commissioner John Koskinen, and former Treasury Secretary Jacob Lew. The en banc Eleventh Circuit interpreted 18 U.S.C. § 1521 and held that its reference to an “officer or employee of the United States” does not include a person who had already left federal service when the lien was filed. It vacated the four convictions involving Koskinen and Lew and remanded for resentencing, while leaving the remaining convictions undisturbed.