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Thompson v. United States

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Supreme Court of the United States
Thompson v. United States
Term: 2024
Important Dates
Argued: January 14, 2025
Decided: March 21, 2025
Outcome
vacated and remanded
Vote
9-0
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson
Concurring
Samuel Alito • Ketanji Brown Jackson

Thompson v. United States is a case that was decided by the Supreme Court of the United States on March 21, 2025, during the court's October 2024-2025 term. The case was argued before the Supreme Court of the United States on January 14, 2025.

In a 9-0 opinion, the court vacated and remanded the judgment of the United States Court of Appeals for the Seventh Circuit, holding that 18 U.S.C. § 1014, which penalizes individuals for making false statements, does not criminalize statements that are misleading but true. Chief Justice John Roberts delivered the opinion of the court.[1]

HIGHLIGHTS
  • The issue: The case concerned whether making a false statement, as defined in 18 U.S.C § 1014, includes statements that are misleading, but not necessarily false. Click here to learn more about the case's background.
  • The questions presented: "Whether 18 U.S.C. § 1014, which prohibits making a "false statement" for the purpose of influencing certain financial institutions and federal agencies, also prohibits making a statement that is misleading but not false."[2]
  • The outcome: In a 9-0 opinion, the court vacated and remanded the judgment of the United States Court of Appeals for the Seventh Circuit.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the Seventh Circuit. To review the lower court's opinion, click here.

    Background

    Case summary

    The following are the parties to this case:[3]

    • Petitioner: Patrick D. Thompson
      • Legal counsel: Stuart Banner (UCLA School of Law Supreme Court Clinic)
    • Respondent: United States

    The following summary of the case was published by Oyez, a free law project from Cornell’s Legal Information Institute, Justia, and the Chicago-Kent College of Law:[5]

    “

    Patrick Thompson took out three loans from Washington Federal Bank for Savings between 2011 and 2014, totaling $219,000. In late 2017, Washington Federal failed, and the Federal Deposit Insurance Corporation (FDIC) became its receiver, hiring Planet Home Lending to service the loans. Thompson received an invoice showing a loan balance of $269,120.58, which included interest.

    In subsequent phone calls with Planet Home and FDIC contractors in February and March 2018, Thompson disputed the higher balance. He acknowledged borrowing money but claimed he had only borrowed $110,000, omitting mention of the two additional loans. When the contractors found out about Thompson’s 2013 and 2014 loans shortly thereafter, they called Thompson back on March 5, 2018, he again expressed doubt over the accuracy of the higher loan balance. Eventually, Thompson and the FDIC agreed to settle his debt for $219,000—the amount Thompson owed without interest in December 2018.

    In April 2021, a grand jury charged Thompson with two counts of violating 18 U.S.C. § 1014—a statute that criminalizes making a “false statement . . . for the purpose of influencing in any way the action” of the FDIC or a mortgage lending business. After a six-day trial, a jury convicted Thompson of both counts, and the U.S. Court of Appeals for the Seventh Circuit affirmed.[6]

    		”

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether 18 U.S.C. § 1014, which prohibits making a "false statement" for the purpose of influencing certain financial institutions and federal agencies, also prohibits making a statement that is misleading but not false.[6] ”

    Oral argument

    Audio

    Audio of oral argument:[8]




    Transcript

    Transcript of oral argument:[9]

    Outcome

    In a 9-0 opinion, the court vacated and remanded the judgment of the United States Court of Appeals for the Seventh Circuit, holding that 18 U.S.C. § 1014, which penalizes individuals for making false statements, does not criminalize statements that are misleading but true. Chief Justice John Roberts delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Chief Justice John Roberts wrote:[1]

    “

    In casual conversation, people use many overlapping words to describe shady statements: false, misleading, dishonest, deceptive, literally true, and more. Only one of those words appears in the statute. Section 1014 does not criminalize statements that are misleading but true. Under the statute, it is not enough that a statement is misleading. It must be “false.” The judgment of the Court of Appeals for the Seventh Circuit is vacated, and the case is remanded for further proceedings consistent with this opinion. [6]

    		”
    —Chief Justice John Roberts

    Concurring opinion

    Justice Samuel Alito

    Justice Samuel Alito filed a concurring opinion.

    In his concurring opinion, Justice Alito wrote:[1]

    “

    In ordinary speech, we do not regard a statement as true or false based solely on the literal or semantic meaning of its words viewed in isolation. Two examples illustrate this principle. Start with an example adapted from the parties’ briefs. See Brief for United States 16; Reply Brief 8–9. After noticing that a plate of 12 fresh-baked cookies has only crumbs remaining, a mother asks her daughter, “Did you eat all the cookies?” If the child says “I ate three” when she actually had all 12, her words would be literally true in isolation but false in context. The child did eat three cookies (then nine more). In context, however, the child is implicitly saying that she ate only three cookies, and that is false.

    Consider another example, adapted from a law-review article by Professor Richard Fallon. See The Statutory Interpretation Muddle, 114 Nw. U. L. Rev. 269, 272 (2019). Parents James and Rachel are talking about their teenage son Alex. James enlists Alex to help rake leaves, but Alex is distracted and does little work. Afterwards, James tells Rachel: “As usual, Alex was a big help.” Taken literally, his statement is false. But if James and Rachel have often spoken about Alex’s unwillingness to help with household chores, Rachel would understand that James’s statement was ironic and that James actually meant Alex was no help at all. So, in context, James’s statement is actually true.

    Petitioner readily acknowledges that falsity must be judged in context. See Reply Brief 7–8; Tr. of Oral Arg. 6– 7. Courts should keep this important point in mind in future §1014 cases [6]

    		”
    —Justice Samuel Alito

    Justice Ketanji Brown Jackson

    Justice Ketanji Brown Jackson filed a concurring opinion.

    In her concurring opinion, Justice Jackson wrote:[1]

    “

    I agree with the Court’s conclusion that 18 U. S. C. §1014 criminalizes only false statements. Ante, at 10. I write separately to note that the pre-verdict instructions the District Court provided to the jury in this case did not say otherwise. That is, while the lower courts may have misunderstood the scope of §1014, the jury was properly instructed that it could find Thompson guilty only if the prosecution proved beyond a reasonable doubt that Thompson “made the charged false statement[s].” App. 157–158. For count two, the jury specifically found that Thompson made all of the statements alleged. Id., at 160. Moreover, and importantly, the jury was not advised that §1014 “criminalizes misleading representations,” 89 F. 4th 1010, 1016 (CA7 2024), as was mistakenly required by the Seventh Circuit precedent the Court rejects today.

    Thus, in my view, there is little for the Seventh Circuit to do on remand but affirm the District Court’s judgment upholding the jury’s guilty verdict. Whether Thompson’s statements were, in fact, false is a question for the jury— and here, one the jury has already answered. At most, then, the Seventh Circuit can properly assess whether any reasonable jury could have found that Thompson’s statements satisfied §1014’s falsity element. On this record, I think that legal issue is not subject to reasonable debate. [6]

    		”
    —Justice Ketanji Brown Jackson

    Text of the opinion

    Read the full opinion here.

    October term 2024-2025

    See also: Supreme Court cases, October term 2024-2025

    The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[10]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 U.S. Supreme Court, "Thompson v. United States," March 21, 2025
    2. ↑ 2.0 2.1 Supreme Court of the United States, "23-1095 THOMPSON V. UNITED STATES QP", October 4, 2024
    3. ↑ Supreme Court of the United States, "No. 23-1095," accessed November 20, 2024
    4. ↑ Note: At the time that the Court heard this case's argument, legal counsel was provided by then-U.S. Solicitor General Elizabeth B. Prelogar. Prelogar stepped down from her position on January 20, 2025, following the swearing-in of President Donald Trump (R) to his second term. After taking office, Trump appointed Sarah M. Harris to serve as the acting U.S. Solicitor General until her successor is confirmed and sworn in.
    5. ↑ Oyez, "Thompson v. United States," accessed November 20, 2024
    6. ↑ 6.0 6.1 6.2 6.3 6.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ United States Court of Appeals for the Seventh Circuit, United States v. Thompson, decided January 8, 2024
    8. ↑ [https://www.supremecourt.gov/oral_arguments/audio/2024/23-1095 Supreme Court of the United States, "Oral Argument - Audio," argued January 14, 2025 ]
    9. ↑ [https://www.supremecourt.gov/oral_arguments/argument_transcripts/2024/23-1095_a86c.pdf Supreme Court of the United States, "Oral Argument - Transcript," argued January 14, 2025 ]
    10. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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