In United States v. Pate, No. 20-10545 (Oct. 11, 2023), the en banc Court--in an opinion authored by Judge Newsom--vacated Mr. Pate's § 1521 convictions and remanded for resentencing.   Mr. Pate filed liens against property owned by a number of people he thought wronged him, including a former Commissioner of the IRS and a former Secretary [...]