Patrick D. Thompson, Petitioner v. United States

The Supreme Court ruled unanimously that a federal law against making false statements to banks does not cover statements that are merely misleading but factually true. The Court found that the word 'false' in the law means 'not true,' and because Congress did not include the word 'misleading,' the law only applies to actual lies.

This decision limits the power of federal prosecutors to charge people with fraud for being deceptive if their statements are technically accurate. It protects individuals from criminal charges for 'half-truths' when dealing with financial institutions or the FDIC.

The case centers on 18 U.S.C. § 1014, a law used to punish people who try to influence banks with dishonest information. The Court focused on a strict reading of the text, noting that Congress knows how to include 'misleading' in laws when it wants to, but chose not to do so here.

Chief Justice John Roberts wrote the opinion for a unanimous Court, with Justices Alito and Jackson each writing separate concurring opinions.

“The term 'false' in § 1014 means 'not true,' excluding statements that are misleading but factually accurate.”

The Supreme Court held that being misleading is not the same as lying under federal bank fraud laws.

The case returns to the lower courts to determine if Thompson's specific statements were actually false or just misleading. Prosecutors must now prove a statement is factually untrue to win a conviction under this specific statute.

The dispute was whether a law banning 'false statements' to banks also covers 'misleading' statements. Thompson argued that his statements were technically true even if they were confusing.

Customers cannot be prosecuted under this specific law for providing information that is technically accurate but potentially deceptive. It sets a higher bar for the government to prove criminal intent.

The Court established that 'false' means 'not true' in the context of § 1014. It refused to add a 'materiality' requirement or expand the definition to include misleading truths.

The Supreme Court vacated the lower court's decision and remanded (sent back) the case. The lower courts must now decide if Thompson's statements were factually false.

The ruling follows a trend of the Court strictly following the literal text of laws. The justices argued that if Congress wanted to ban misleading statements, it would have said so.