Yates v. United States, 574 U.S. 528 (2015)
Yates v. United States is a leading Supreme Court decision at the intersection of criminal law and statutory interpretation.
Does the term "tangible object" in 18 U.S.C. §1519, a Sarbanes-Oxley obstruction provision, encompass a fish such that throwing undersized fish overboard constitutes destruction of a "tangible object" within the meaning of the statute?
Interpreting 18 U.S.C. §1519 in context, the term "tangible object" refers to an object used to record or preserve information. When statutory language is ambiguous, courts may use canons of construction such as noscitur a sociis (a word is known by the company it keeps) and ejusdem generis (general words are limited by specific words preceding them) to understand its scope, and in the criminal context apply the rule of lenity to resolve reasonable doubt in favor of the defendant.
No. The term "tangible object" in §1519 does not include fish; it covers objects used to store or record information. Yates's conviction under §1519 was reversed.
Yates is a touchstone for statutory interpretation in criminal cases. It underscores that context—not isolated dictionary definitions—can delimit seemingly broad statutory terms, especially when neighboring words, statutory titles, and structure signal a narrower domain. The case also exemplifies the rule of lenity's continued vitality when competing readings remain plausible. For law students, Yates highlights interpretive method differences: the plurality's and concurrence's context- and purpose-driven reading versus the dissent's textual literalism. Practically, Yates cabins §1519 to record-like objects, curbing the statute's potential use as a catch-all obstruction charge for destruction of any physical item. Because the Court fractured 4–1–4, Justice Alito's concurrence represents the controlling rationale under Marks, emphasizing narrow, context-specific grounds.