// Walk the loop, step by step
01
Verifiable
2017-05-22
MCAS entered service without adequate pilot training or FAA disclosure of its full authority.
EvidenceHouse T&I Committee 'Final Report on the Design, Development, and Certification of the Boeing 737 MAX' (Sep 2020) documents the chain of disclosure failures and FAA's reliance on Boeing's Organization Designation Authorization (ODA) personnel.
02
Verifiable
2016-11-15
Boeing's technical pilots communicated MCAS concerns internally before the crashes.
EvidenceThe 2016 internal Boeing chat between Mark Forkner (chief technical pilot) and a colleague — 'so basically I lied to the regulators (unknowingly)' — was disclosed to DOJ in 2019 and released publicly. Multiple internal communications document the concerns predating service entry.
03
Verifiable
2021-01-07
DOJ enters a $2.5B DPA with Boeing in January 2021. Single indictment of one technical pilot; senior leadership unprosecuted.
EvidenceDOJ's 2021 deferred prosecution agreement: $243.6M criminal monetary penalty, $1.77B compensation to airlines, $500M crash victim beneficiaries fund, and a 3-year monitoring period. Mark Forkner indicted and later acquitted (2022). No senior executive prosecuted.
04
Verifiable
2019-12-23
$62M
Boeing's CEO Dennis Muilenburg received ~$62M severance after termination.
EvidenceBoeing 8-K and 2020 proxy statement disclose Muilenburg's separation payments — pension, equity, accumulated benefits. The number is widely reported but always derived from these public filings.
05
Verifiable
2024-05-14
The 2024 DPA breach finding: DOJ concludes Boeing violated the agreement.
EvidenceMay 2024: DOJ files a notice that Boeing breached the 2021 DPA by failing to design and implement an effective compliance and ethics program. The breach exposes Boeing to renewed prosecution; settlement negotiations remain ongoing as of records release.
// What this documents
The 737 MAX file documents a corporate-fraud arc that landed at a deferred prosecution agreement — the policy default for major-corporate criminal conduct since 2003 (the post-Andersen 'collateral consequences' doctrine). The DPA's structural problem is publicly visible: monetary penalties dwarf executive compensation but rarely change the operating procedures that produced the underlying harm. The 2024 breach finding is the most recent piece of that pattern.
// Federal statutes implicated
// What public records cannot prove on their own
Individual prosecution of senior executives requires either (a) direct evidence the senior executive knew of and approved the false statement, or (b) a willful-blindness theory the courts have grown skeptical of since the Andersen reversal. Boeing's compartmentalized engineering and certification org structure makes (a) difficult to assemble; the post-Yates Memo culture has not, in practice, produced senior-executive indictments at this scale.
GOBLIN HOUSE
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