Thompson v. United States

Title 18 U.S.C. § 1014, which prohibits “knowingly mak[ing] any false statement,” does not criminalize statements that are misleading but not false. Chief Justice John Roberts authored the unanimous opinion of the Court. The term “false” in § 1014 means “not true,” excluding statements that are misleading but factually accurate. The statute does not use the word “misleading,” even though Congress has included that term in other statutes when intending to criminalize deceptive but true statements. Because misleading statements are sometimes true, they do not fit within § 1014’s prohibition on “false statements.” The statutory context confirms this interpretation, as a broad reading that includes misleading statements would render other statutes’ use of both “false” and “misleading” redundant. Precedent further supports this distinction. The Court in United States v. Wells concluded that § 1014 does not have an unwritten materiality requirement because Congress did not include that term in the statute. Similarly, § 1014 does not encompass misleading statements simply because they might deceive. The Court rejected the government’s reliance on Kay v. United States, explaining that Kay primarily discussed false statements made with intent to mislead, not statements that were misleading but true. Because neither the district court nor the Seventh Circuit determined whether Thompson’s statements were false, the Court remanded for further proceedings on that issue.