Shaw v. United States

Lawrence Shaw was convicted under the federal bank fraud statute, 18 U.S.C. § 1344(1), for executing a scheme to transfer funds from a Bank of America depositor's account to his own using fraudulently obtained account credentials. Shaw appealed, arguing that he intended only to cheat the depositor, not the bank, and that the bank suffered no risk of financial loss. The United States Court of Appeals for the Ninth Circuit affirmed the conviction, and the Supreme Court granted certiorari. On December 12, 2016, the Supreme Court issued an 8-0 decision holding that the statute does not require the government to prove that a defendant intended to cause the bank monetary harm. The Court ruled that the law is satisfied by an intent to deceive the bank and obtain its property, here the funds held in the deposit account, even if the bank ultimately faces no loss.

The Supreme Court unanimously affirmed the Ninth Circuit. It held that a conviction under 18 U.S.C. § 1344(1) does not require proof of intent to cause the bank a financial loss; the government need only show that the defendant intended to deceive the bank and to acquire property under its custody or control through fraud.

Whether the federal bank fraud statute, 18 U.S.C. § 1344(1), requires proof of an intent to cause financial loss to the bank, or whether it is sufficient to prove only an intent to deceive the bank and obtain its property through fraudulent means.

The ruling clarified the evidentiary burden in bank fraud prosecutions, confirming that the statute targets the misuse of a bank's property interest in deposited funds rather than exclusively the bank's own money. It strengthened the ability of federal prosecutors to pursue white-collar cases where a defendant acts with an intent to deceive a financial institution, even if the institution is not the ultimate target of financial harm, and reinforced the broad protective scope of financial fraud laws.