The borrower received three loans from a single bank totaling $219,000. The bank failed, and the Federal Deposit Insurance Corporation (FDIC) became responsible for collecting on the loans. In conversations with the bank and the FDIC, the borrower claimed he had taken out a $110,000 loan and did not know where the larger number came from. The borrower did, in fact, take out a $110,000 loan; however, later the borrower took out two additional loans for $20,000 and $89,000, respectively. The FDIC brought claims against the borrower under 18 U.S.C. § 1014, which prohibits “‘knowingly mak[ing] any false statement or report . . . for the purpose of influencing in any way the action of . . . the [FDIC] . . . upon any . . . loan.’” The district court found the borrower guilty. The borrower then moved for acquittal, arguing that he could not be found guilty under § 1014 for false statements because the alleged statements are factually true. The district court denied the borrower’s motion, finding that “‘the Seventh Circuit does not require literal falsity in Section 1014 cases.’” The district court acknowledged that the borrower’s argument would carry more weight in the Sixth Circuit but declined to review whether the borrower’s statements were literally false, as the Seventh Circuit had previously decided that § 1014 applies to misleading statements as well. The Seventh Circuit affirmed, and the Supreme Court granted certiorari to determine whether § 1014 criminalizes statements that are misleading but not false.
In Thompson v. U.S., 604 U.S. 408 (2025), the Supreme Court held that §1014 “does not criminalize statements that are misleading but not false” and reversed and remanded for further proceedings. The Supreme Court first examined the plain text of § 1014 and found it requires both: (1) that a statement was made and (2) that the statement can be characterized as either true or false. The Court clarified that a misleading statement, if not actually false, would not meet the criteria for a conviction under § 1014 because the plain text requires the statement to be false. The Court explained that the correct question in this case was whether the borrower's statements were false, because people can make statements that are misleading but still true, and § 1014 addresses only false statements. Finally, the Court emphasized that it is a court of review and that, since neither the district court nor the Seventh Circuit had addressed the falsity of the statements, the case had to be remanded for further review consistent with its holding.
By Noah Coggan [email protected]
Edited By Jace Brown [email protected]
Edited By Kristin Meurer [email protected]
Edited By Hayden Mariott [email protected]