Yates v. United States

Whether 18 U.S.C. § 1519 makes it an offense to destroy any tangible objects with the intent to impede an investigation or administrative matter, or whether the statute is limited to tangible objects related to records or documents.

Petitioner was fined while at sea for catching prohibited undersized fish in the Gulf of Mexico. Petitioner was ordered to bring the undersized fish back to port with him, but he disposed of those fish while at sea. Upon his return to port, he was charged and convicted of violating of 18 USC § 1519 for destroying or concealing any tangible object, and USC § 2232(a) for knowingly disposing of undersize fish. The Eleventh Circuit affirmed Petitioner's conviction, and held that the trial court correctly interpreted § 1519, which made it a criminal offense to knowingly alter, destroy, or conceal any record, document, or tangible object with the intent to impede an investigation or administrative matter. The Supreme Court granted certiorari to answer the question of whether the Eleventh Circuit interpreted § 1519 correctly.

Petitioner argued that as § 1519 was enacted as part of the Sarbanes-Oxley Act, it was only meant to apply to documents and objects used for recording, documentary, or informative purposes. The Eleventh Circuit did not consider the legislative intent, but interpreted the statute’s words and held that the language of the statute was clearly unambiguous, and that the ordinary meaning courts give to "tangible object” is anything with physical form.