Statutory Interpretation Flashcards
(8 cards)
What was the central issue in Yates v. United States (2015)?
Whether a fish is a ‘tangible object’ under 18 U.S.C. §1519 (Sarbanes-Oxley Act).
What was the context of Yates v. United States?
Yates, a fisherman, threw undersized fish overboard to avoid penalties. Prosecutors charged him under a provision of SOX that prohibits destroying ‘tangible objects’ to impede an investigation.
What was the holding in Yates v. United States?
5-4 decision that ‘tangible object’ in this context only refers to objects used to record or preserve information, not all physical objects.
Explain noscitur a sociis as used in Yates v. United States.
Noscitur a sociis - ‘a word is known by the company it keeps’
The majority argued that ‘tangible object’ should be interpreted in light of the words around it (‘records’ and ‘documents’), suggesting it only includes information-storage objects.
What quote did Justice Ginsburg provide regarding noscitur a sociis?
‘We rely on the principle of noscitur a sociis to ‘avoid ascribing to one word a meaning so broad that it is inconsistent with its accompanying words.’
Compare textualist vs. purposivist approaches to statutory interpretation in Yates v. United States.
Textualist (Kagan’s dissent): Focused on plain, ordinary meaning of ‘tangible object’, relied on dictionary definitions, argued fish clearly fit the definition as physical objects, rejected limiting meaning based on context/purpose.
Purposivist (Ginsburg’s majority): Considered why Congress passed Sarbanes-Oxley (Enron scandal), used statutory context and placement, applied canons like noscitur a sociis and ejusdem generis, concluded ‘tangible object’ only meant information-storage items.
What rule of lenity argument did the majority use in Yates?
The majority argued that if ambiguity remained after applying traditional tools of statutory construction, the rule of lenity would favor the defendant.
The rule requires that ‘ambiguity concerning the ambit of criminal statutes should be resolved in favor of lenity’ to ensure fair warning and proper balance between legislature, prosecutor, and courts.
