Yates v. United States
United States Supreme Court
574 U.S. 528, 135 S.Ct. 107, 191 L.Ed.2d 64 (2015)
- Written by Eric Cervone, LLM
Facts
John Yates (defendant), a commercial fisherman, caught undersized red grouper in federal waters in the Gulf of Mexico in violation of federal conservation regulations. To prevent federal authorities from confirming that he had caught the fish, Yates ordered a crew member to toss the fish back into the water. As a result, Yates was charged with violating a provision of the Sarbanes-Oxley Act (Act), 18 U.S.C. § 1519, which criminalized the destruction or concealment of any record, document, or tangible object to obstruct a federal investigation. At trial, Yates argued that § 1519 did not apply to throwing fish overboard in a commercial-fishing context. The government disagreed and claimed that fish were a tangible object within the purview of § 1519. Yates was convicted and sentenced to 30 days of imprisonment. Yates appealed. The court of appeals affirmed. The United States Supreme Court granted certiorari to review.
Rule of Law
Issue
Holding and Reasoning (Ginsburg, J.)
Concurrence (Alito, J.)
Dissent (Kagan, J.)
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