United States v. Santos (2007)
- Docket
- 06-1005
- Decided
- 2007-01-01
Summary
Question: In the federal money laundering statute 18 U.S.C. 1956(a)(1), which makes it a crime to use the proceeds of an illegal activity to promote the activity or conceal the proceeds, does the word "proceeds" refer to the gross income received from the illegal activity or to the net income (profits, or gross income minus expenses)? Conclusion: Splitting 5 to 4, the Court affirmed the Seventh Circuit, answering that "proceeds" refers to "net income" or profits and not to "gross income." Because the statute nowhere defines the term "proceeds", the plurality applied the so-called rule of lenity which requires such ambiguous statutes to be interpreted in favor of defendants. Justice Antonin Scalia announced the judgment and wrote a plurality opinion for himself and three other justices. Justice John Paul Stevens concurred in the judgment. Justice Samuel Alito wrote a dissenting opinion, joined by Chief Justice John G. Roberts, Jr., Justices Anthony Kennedy and Stephen G. Breyer.