Yates v. United States

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Criminal Law
  • Date Filed: February 25, 2015
  • Case #: 13-7451
  • Judge(s)/Court Below: Ginsburg, J., announced the judgment of the Court and delivered an opinion, in which Roberts, C. J., and Breyer and Sotomayor, JJ., joined. Alito, J., filed an opinion concurring in the judgment. Kagan, J., filed a dissenting opinion, in which Scalia, Kennedy, and Thomas, JJ., joined.
  • Full Text Opinion

"Tangible object," as used in 18 USC § 1519 and elsewhere in the Sarbanes-Oxley Act of 2002, refers to a physical object capable of recording or preserving information.

Petitioner was cited for possession of prohibited fish during an inspection of his commercial fishing vessel. Petitioner was order to store the fish, but instead disposed of the evidence before returning to port. In response, Petitioner was charged and convicted of violating 18 USC § 1519, which imposes a criminal penalty for destroying tangible objects with the intent to impede federal investigations. The Eleventh Circuit affirmed, holding that the plain meaning of “tangible object” was to apply to any physical object that is not a “document” or a “record.”

The Supreme Court reverses the Eleventh Circuit, holding that § 1519 uses “tangible object” to refer to an object involving records or documents, i.e. a physical object capable of recording or preserving information. The section’s language, the Sarbanes-Oxley Act, the section’s caption, its placement in the U.S. Code, and canons of construction all directed the Court to interpret the definition narrowly; noting that one who “falsifies, or makes a false entry in any … tangible object” can only do so if that object can be falsified or contain false entries when recording or preserving information. Finally, as a criminal statute, the Rule of Lenity favors the narrow interpretation of the term.

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