Yates v. United States

Citation

574 U.S. 528 (2015)

Facts

Stub — to be completed.

Issue

Stub — to be completed.

Holding

Stub — to be completed.

Rule

The term “tangible object” in 18 U.S.C. § 1519 (the Sarbanes-Oxley anti-shredding provision) is limited to objects used to record or preserve information and does not encompass physical objects unrelated to recordkeeping, such as fish.

Significance

Applied the canon of noscitur a sociis and the rule of lenity to narrow § 1519, rejecting the government’s broad reading; illustrates the Court’s use of statutory context and canons to limit federal criminal statutes.

Courses