John L. Yates captained a commercial fishing vessel in the Gulf of Mexico when a Florida Fish and Wildlife Conservation Commission officer, deputized to enforce federal fisheries regulations, boarded the boat and measured several red grouper. The officer identified some fish as undersized under federal conservation rules, issued Yates a civil citation, and ordered him to segregate the undersized catch in crates and bring them intact to port for remeasurement. After the officer departed, Yates instructed his crew to dispose of the undersized fish overboard and to replace them with larger fish. On arrival, federal authorities discovered discrepancies between the fish initially measured and those in the segregated crates. Federal prosecutors charged Yates with violating 18 U.S.C. §1519 (enacted as part of the Sarbanes-Oxley Act to deter destruction of records and evidence) for destroying a "tangible object" with intent to impede a federal investigation, and with violating 18 U.S.C. §2232(a) (destruction of property to prevent seizure). A jury convicted him on both counts, and the Eleventh Circuit affirmed. The Supreme Court granted certiorari to decide whether a fish is a "tangible object" under §1519.
Does the term "tangible object" in 18 U.S.C. §1519, a Sarbanes-Oxley obstruction provision, encompass a fish such that throwing undersized fish overboard constitutes destruction of a "tangible object" within the meaning of the statute?
Interpreting 18 U.S.C. §1519 in context, the term "tangible object" refers to an object used to record or preserve information. When statutory language is ambiguous, courts may use canons of construction such as noscitur a sociis (a word is known by the company it keeps) and ejusdem generis (general words are limited by specific words preceding them) to understand its scope, and in the criminal context apply the rule of lenity to resolve reasonable doubt in favor of the defendant.
No. The term "tangible object" in §1519 does not include fish; it covers objects used to store or record information. Yates's conviction under §1519 was reversed.
Plurality (Ginsburg, joined by Roberts, Breyer, and Sotomayor): The Court emphasized statutory context and purpose. Section 1519, enacted in Sarbanes-Oxley's wake to close gaps exposed by the Enron scandal, targets the destruction of financial records and other evidence of corporate fraud. The statutory phrase prohibits altering or destroying any "record, document, or tangible object." Applying noscitur a sociis, the plurality reasoned that "tangible object" should be read alongside "record" and "document," indicating a class of items used to preserve information. Verbs in the statute such as "falsifies" and "makes a false entry" also fit naturally with recordkeeping media, not with physical items like fish. The provision's title—"Destruction, alteration, or falsification of records in Federal investigations and bankruptcy"—and its placement in a chapter focused on "records and files" reinforce a records-centric scope. Reading "tangible object" to cover any physical object would make the statute "far-reaching" and untethered from Sarbanes-Oxley's focus. At a minimum, ambiguity about the breadth of "tangible object" triggers the rule of lenity, favoring a narrower construction in criminal cases. Concurrence in the judgment (Alito): Justice Alito agreed that context controls and found several features dispositive: the caption and placement in a records-focused chapter; the accompanying words "record" and "document"; and the mismatch between verbs like "falsify" and "make a false entry" and non-record items. While acknowledging "tangible object" could plausibly be read broadly, these contextual cues and the rule of lenity required a narrower reading limited to information-preserving objects. Dissent (Kagan, joined by Scalia, Kennedy, and Thomas): The dissent argued that the ordinary meaning of "tangible object" plainly covers a fish—"a fish is, of course, a tangible object." The statute's use of "any" before "record, document, or tangible object" underscores breadth, and Congress knows how to write narrowly when it wishes. The dissent criticized the majority for departing from clear text based on purpose and legislative history, and dismissed reliance on the title and placement as insufficient to overcome plain meaning. In the dissent's view, canons should not be used to rewrite an unambiguous statute, and concerns about overbreadth or prosecutorial discretion are for Congress, not the courts.
Yates is a touchstone for statutory interpretation in criminal cases. It underscores that context—not isolated dictionary definitions—can delimit seemingly broad statutory terms, especially when neighboring words, statutory titles, and structure signal a narrower domain. The case also exemplifies the rule of lenity's continued vitality when competing readings remain plausible. For law students, Yates highlights interpretive method differences: the plurality's and concurrence's context- and purpose-driven reading versus the dissent's textual literalism. Practically, Yates cabins §1519 to record-like objects, curbing the statute's potential use as a catch-all obstruction charge for destruction of any physical item. Because the Court fractured 4–1–4, Justice Alito's concurrence represents the controlling rationale under Marks, emphasizing narrow, context-specific grounds.
Yates v. United States stands as a prominent reminder that words live in context. Even broad terms like "tangible object" can be cabined by neighboring text, statutory structure, and legislative purpose—particularly in criminal statutes where liberty is at stake. The Court's reliance on canons such as noscitur a sociis and ejusdem generis, along with the rule of lenity, charted a path that avoids converting Sarbanes-Oxley into an all-purpose obstruction tool unmoored from record destruction.