Thompson v. United States
604 U.S. 408
SCOTUS2025Background
- Patrick Thompson took out three loans from the same bank, totaling $219,000.
- After the bank failed, the FDIC took over loan collection, and Thompson disputed the invoiced balance by claiming he had borrowed only $110,000.
- Thompson repeated the $110,000 claim in further communications with the FDIC and its contractors.
- He was charged under 18 U.S.C. §1014 with making false statements to influence the FDIC regarding a loan.
- Both the District Court and Seventh Circuit held that §1014 covers misleading as well as false statements and found Thompson's statements at least misleading.
- The Supreme Court granted certiorari to determine whether §1014 criminalizes merely misleading (but not false) statements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does §1014 criminalize misleading but not false statements? | Thompson argued only literally false statements can support a conviction under §1014. | United States argued §1014 includes misleading statements that are not literally false. | No, §1014 only criminalizes statements that are actually false, not merely misleading. |
| Was Thompson's statement "I borrowed $110,000" false under §1014? | Argued the statement was literally true, as he did borrow $110,000, despite other loans. | Argued the statement was misleading and implied a lower total debt, thus should count. | Remanded for the lower court to decide if a reasonable jury could find the statements were false, not just misleading. |
Key Cases Cited
- United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (statutory construction: syllabus not part of opinion)
- United States v. Wells, 519 U.S. 482 (materiality is not incorporated unless statute requires it)
- Williams v. United States, 458 U.S. 279 (a check is not a false statement under §1014)
- Brogan v. United States, 522 U.S. 398 (defines "any false statement" as a statement that is false, of whatever kind)
- Victor v. Nebraska, 511 U.S. 1 (basic logic regarding truth and falsity)
- Custis v. United States, 511 U.S. 485 (Congress knows how to include broader language when intended)
- Gustafson v. Alloyd Co., 513 U.S. 561 (courts must avoid statutory interpretations that render words superfluous)
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence to support a conviction)