Yates v. United States
574 U. S. ____ (2015) (2015)
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Rule of Law:
The term "tangible object" as used in 18 U.S.C. § 1519, an anti-shredding provision of the Sarbanes-Oxley Act, is limited to objects used to record or preserve information and does not encompass all physical objects.
Facts:
- John Yates, the captain of a commercial fishing boat, was operating in the Gulf of Mexico in August 2007.
- During an inspection, a deputized federal agent, Officer John Jones, determined that Yates's crew had caught 72 red grouper that were below the legal minimum size of 20 inches.
- Officer Jones ordered Yates to keep the undersized fish segregated in wooden crates on the boat until it returned to port.
- Before returning to port, Yates instructed a crew member to throw the undersized fish overboard.
- Yates and the crew member then replaced the discarded fish with other fish from the main catch that were slightly larger, though still under the legal limit, to conceal the violation.
Procedural Posture:
- The United States government indicted John Yates in the U.S. District Court for the Middle District of Florida, a federal trial court.
- Yates was charged with violating 18 U.S.C. § 2232(a) and 18 U.S.C. § 1519.
- At the close of the government's case, Yates moved for a judgment of acquittal on the § 1519 charge, arguing that fish were not 'tangible objects' under the statute.
- The District Court denied the motion, following controlling circuit precedent.
- A jury convicted Yates on both counts.
- Yates (as appellant) appealed his § 1519 conviction to the U.S. Court of Appeals for the Eleventh Circuit, arguing against the government (as appellee).
- The Eleventh Circuit affirmed the conviction, holding that the plain meaning of 'tangible object' was unambiguous and included fish.
- The U.S. Supreme Court granted Yates's petition for a writ of certiorari.
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Issue:
Does the term "tangible object" in 18 U.S.C. § 1519, which prohibits the destruction of evidence to impede a federal investigation, cover all physical objects, including fish, or is its scope limited to objects related to recording or preserving information?
Opinions:
Plurality - Justice Ginsburg
No. The term "tangible object" in § 1519 must be read in its statutory context to refer only to objects used to record or preserve information, not all physical items. The Court reasoned that § 1519 was enacted as part of the Sarbanes-Oxley Act, which was a response to the Enron scandal and specifically targeted the destruction of financial records and corporate documents. Applying canons of statutory construction like noscitur a sociis (a word is known by the company it keeps) and ejusdem generis, the Court found that "tangible object" is the last in a list following "any record [or] document," suggesting it refers to items of the same class. Furthermore, the verbs used in the statute, such as "falsifies" and "makes a false entry in," are most naturally applied to information-storage devices, not physical objects like fish. Reading the term to cover all objects would also render another contemporaneously enacted statute, § 1512(c)(1), largely superfluous. Finally, the rule of lenity dictates that ambiguity in a criminal statute should be resolved in favor of the defendant, especially when the government's broad interpretation would subject individuals to a 20-year felony for conduct far removed from the statute's core purpose.
Concurring - Justice Alito
No. The term "tangible object" in § 1519 does not include fish. This conclusion is based on the combination of three textual features of the statute. First, the list of nouns—"record, document, or tangible object"—suggests, via the noscitur a sociis canon, that a "tangible object" must be something similar to a record or document. Second, the list of verbs, which includes "falsifies" and "makes a false entry in," is most naturally associated with file-keeping and information storage. Third, the statute's title, "Destruction, alteration, or falsification of records...," reinforces the interpretation that the section is concerned with records and information, not all physical objects. While none of these features alone is dispositive, together they make the government's broad reading implausible.
Dissenting - Justice Kagan
Yes. The term "tangible object" in § 1519 should be given its ordinary and plain meaning, which is any physical object that can be touched, including a fish. The statute's text is broad but clear, using the expansive word "any" to modify "tangible object." This broad reading is consistent with the term's use in numerous other federal and state laws, which have never been limited to information-storage devices. Congress's purpose in enacting § 1519 was to close a loophole in existing law and create a broad prohibition against destroying any physical evidence to thwart an investigation. The plurality's reliance on canons of construction is improper because they should not be used to create ambiguity where the text is clear. Concerns about overcriminalization or excessive penalties are matters for Congress to address, and do not give the Court license to rewrite a statute with clear, unambiguous text.
Analysis:
This case is a significant modern example of statutory interpretation, highlighting the conflict between textualist and purposivist approaches. The plurality's decision demonstrates the power of contextual analysis and canons of construction, such as noscitur a sociis, to narrow the scope of a broadly worded criminal statute to align with its perceived legislative purpose. The ruling prevents the government from using the Sarbanes-Oxley Act's anti-shredding provision as an all-purpose tool against evidence tampering, limiting its application to the financial fraud and document destruction context for which it was designed. The sharp division on the Court illustrates the ongoing debate over whether to adhere to the plain meaning of statutory text or to interpret it in light of its broader context and purpose to avoid potentially absurd or unduly harsh results.
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