Thompson v. United States

Patrick Thompson took out three loans totaling $219,000 from a bank. After the bank failed, the FDIC took over collection. Thompson disputed a $269,120.58 balance, stating he only borrowed $110,000. He was charged with violating 18 U.S.C. §1014, which prohibits making false statements to influence the FDIC. A jury found him guilty. The Seventh Circuit affirmed, ruling that §1014 criminalizes misleading statements. The Supreme Court granted certiorari.

The Supreme Court unanimously vacated the Seventh Circuit's judgment and remanded the case. The Court held that §1014 does not criminalize misleading but not false statements. Chief Justice Roberts delivered the opinion. Justices Alito and Jackson filed concurring opinions.

Whether 18 U.S.C. §1014, which prohibits making a "false statement," also criminalizes statements that are misleading but not literally false.

The decision narrowed the scope of a federal white-collar criminal statute, emphasizing that "false" and "misleading" are distinct. It reinforced that criminal liability requires literal falsity, not mere misleading conduct. This may limit prosecutorial overreach in financial cases and guide future interpretations of similar statutes. The ruling also highlighted the importance of precise statutory language, as Congress explicitly includes "misleading" in other statutes when intended.