Yates v. United States, 135 S. Ct. 1074

Background

John Yates, captain of the commercial fishing vessel Miss Katie, was inspected in federal waters; an officer found 72 undersized red grouper and ordered they be segregated for return to port.
After the officer left, Yates directed crew to throw the segregated fish overboard and replace them, and was later indicted for (inter alia) violating 18 U.S.C. §1519 (making it a felony to alter/destroy a "record, document, or tangible object" to impede a federal investigation).
Yates moved for acquittal at trial arguing that §1519’s phrase "tangible object" is limited to objects used to record or preserve information (e.g., hard drives, logbooks), not ordinary physical items such as fish; the trial court denied the motion and a jury convicted him.
The Eleventh Circuit affirmed, giving the undefined term its ordinary dictionary meaning (any physical thing) and rejecting a narrower, record-focused reading.
The Supreme Court granted certiorari and reversed: the plurality (Ginsburg) held §1519’s "tangible object" covers only objects used to record or preserve information; the concurrence (Alito) agreed with narrower grounds; Justice Kagan dissented, arguing the ordinary meaning covers all physical objects.

Issues

Issue	Plaintiff's Argument (Yates)	Defendant's Argument (United States)	Held
Whether "tangible object" in 18 U.S.C. §1519 encompasses any physical object (e.g., fish) or only objects used to record/preserve information	"Tangible object" should be read in context with "record, document" and limited to items that store or preserve information (hard drives, logbooks)	The term has its ordinary/dictionary meaning: any physical object; §1519 therefore forbids destruction of any physical evidence to impede federal investigations	Reversed: "tangible object" limited to objects used to record or preserve information (plurality); concurrence agrees on narrower textual canons; dissent would apply ordinary broad meaning
Whether the rule of lenity should apply if ambiguity remains	If doubt exists, resolve ambiguity in favor of defendant (Yates) because §1519 carries severe felony penalties	Argues statutory text is clear and broad so lenity is unnecessary	Court invoked lenity as a backstop but resolved main issue on textual/contextual grounds; plurality noted lenity supports narrowing if ambiguity persisted
Whether §1519’s scope would render other Sarbanes-Oxley provisions (e.g., §1512(c)(1)) superfluous	Narrow reading avoids making §1512(c)(1) redundant and aligns §1519 with the Act’s focus on records-related fraud	§1519’s broader reading is permissible; overlap with §1512(c)(1) is acceptable	Court: placement and contemporaneous enactment of §1512(c)(1) indicate §1519 was not intended as a universal spoliation statute; reject reading that renders §1512(c)(1) superfluous
Whether legislative history / Model Penal Code origins require a broad interpretation	MPC language is not dispositive because §1519 differs materially (severity, scope); Congress targeted records and financial fraud in Sarbanes-Oxley	MPC and prior provisions that used similar phrasing show Congress intended to criminalize spoliation of any physical evidence	Court: MPC origin does not control; significant textual and contextual differences counsel a narrower construction

Key Cases Cited

Robinson v. Shell Oil Co., 519 U.S. 337 (contextual statutory interpretation: plainness/ambiguity measured by text and broader statutory context)
Gustafson v. Alloyd Co., 513 U.S. 561 (use of noscitur a sociis to limit general terms by accompanying specific words)
Marx v. General Revenue Corp., 568 U.S. 371 (canon against surplusage: avoid reading one provision to render another superfluous)
Begay v. United States, 553 U.S. 137 (use of ejusdem generis to interpret general terms following specific enumerations)
Cleveland v. United States, 531 U.S. 12 (rule of lenity applied where statutory ambiguity criminalizes conduct with severe penalties)
Liparota v. United States, 471 U.S. 419 (lenity and fair warning in criminal statutes)