Yates v. United States (2014)
- Docket
- 13-7451
- Decided
- 2014-01-01
Summary
Question: Are fish considered "tangible objects" for the purpose of the statute that makes it a crime to destroy or conceal tangible objects to impede a governmental investigation, even though the term is undefined and exists in a statute that largely refers to record-keeping documents? Conclusion: No. Justice Ruth Bader Ginsburg wrote the opinion for the four-justice plurality. The Court noted that the broad dictionary definition of "tangible objects" would cover fish, but held that the term must be read in the financial context of the Sarbanes-Oxley Act of 2002 (SOX), which was enacted as a reaction to the Enron scandal and contained the specific provision Yates was charged with violating. In this context, the Court held that the term was ambiguous because the caption of the section in question, "Destruction, alteration, or falsification of records in Federal investigations and bankruptcy," and the title of the section in which it was originally placed, "Criminal penalties for altering documents," indicated that Congress was referring only to financial records. Additionally, the section's placement amongst other sections that prohibited specific actions cuts in favor of narrow construction. The Court argued that reading the section to apply to all physical objects would create significant overlap with another section. The words immediately surrounding "tangible object" — "falsifies, or makes a false entry in any record [or] document" —indicated that Congress intended to restrict the term to related objects. Finally, the Court held that any statutory ambiguity in criminal proceedings should be resolved in favor of the defendant. Justice Samuel A. Alito, Jr. wrote an opinion concurring in the judgment in which he argued that the plurality's holding should be narrowly construed. He contended that the statute's list of nouns, its list of verbs, and its title, all working in conjunction, indicated that "tangible object" should be limited to something similar to records or documents. Justice Elena Kagan wrote a dissenting opinion in which she argued that the term "tangible object" should be given its ordinary meaning and therefore subsumes all things that possess physical form, including fish. She noted that the use of the word "any" before "tangible object" demonstrated a congressional intent for broad application. Justice Kagan also pointed out that the section's language tracked the language in other statutes that had been interpreted to include all physical objects. This section's legislative history showed that it was enacted to close a loophole created by another section and therefore did not create any unnecessary overlap. Justice Antonin Scalia, Justice Anthony M. Kennedy, and Justice Clarence Thomas joined the dissent.