Law School Case Brief
Yates v. United States - 574 U.S. 528, 135 S. Ct. 1074 (2015)
The words immediately surrounding "tangible object" in 18 U.S.C.S. § 1519—falsifies, or makes a false entry in any record or document—cabin the contextual meaning of that term. The Supreme Court of the United States relies on the principle of noscitur a sociis—a word is known by the company it keeps—to avoid ascribing to one word a meaning so broad that it is inconsistent with its accompanying words, thus giving unintended breadth to the Acts of Congress. "Tangible object" is the last in a list of terms that begins "any record" or "document." The term is therefore appropriately read to refer, not to any tangible object, but specifically to the subset of tangible objects involving records and documents, i.e., objects used to record or preserve information.
While conducting an offshore inspection of a commercial fishing vessel in the Gulf of Mexico, a federal agent found that the ship's catch contained undersized red grouper, in violation of federal conservation regulations. The officer instructed the ship's captain, petitioner John L. Yates, to keep the undersized fish segregated from the rest of the catch until the ship returned to port. After the officer departed, Yates instead told a crew member to throw the undersized fish overboard. For this offense, Yates was charged with destroying, concealing, and covering up undersized fish to impede a federal investigation, in violation of 18 U.S.C.S. §1519, which provided that a person may be fined or imprisoned for up to 20 years if he "knowingly alters, destroys, mutilates, conceals, covers up, falsifies, or makes a false entry in any record, document, or tangible object with the intent to impede, obstruct, or influence" a federal investigation. At trial in federal district court, Yates filed a motion judgment of acquittal on the §1519 charge. Pointing to §1519's origin as a provision of the Sarbanes-Oxley Act of 2002, a law designed to protect investors and restore trust in financial markets following the collapse of Enron Corporation, Yates argued that §1519's reference to "tangible object" subsumes objects used to store information, such as computer hard drives, not fish. The district court denied Yates's motion, and a jury found him guilty of violating §1519. The United States Court of Appeals for the Eleventh Circuit affirmed the conviction, concluding that §1519 applied to the destruction or concealment of fish because, as objects having physical form, fish fell within the dictionary definition of "tangible object."
Did §1519 apply to the destruction or concealment of fish because fish fell within the dictionary definition of "tangible object?"
The Supreme Court of the United States reversed the appellate court's judgment and remanded the case. The Court held that the Eleventh Circuit erred when it found that Yates violated 18 U.S.C.S. § 1519 because he told a member of his crew to throw undersized fish his crew caught overboard, instead of complying with an order issued by a Florida Fish and Wildlife Conservation Commission officer who was deputized as a federal agent which required him to segregate the undersized fish from other fish and return with them to port. The Court clarified that the term "tangible object" that appeared in § 1519 covered only objects that were used to record or preserve information, not all objects in the physical world, and did not include fish.
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