Here is a summary of the March 21, 2025 Supreme Court opinion in the case called Thompson vs United States, case number 23 1095.

The question presented in this case is whether 18 USC section 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.

Chief Justice Roberts delivered the opinion for a unanimous court.

Justices Alito and Jackson each filed concurring opinions.

Please note that this summary is read by an automated voice Chief Justice Roberts's.

Majority opinion Patrick Thompson took out three loans totaling $219,000 from one bank.

After the bank failed the Federal Deposit Insurance Corporation, FDIC became responsible for collecting the outstanding loans.

During a call with the FDIC's loan servicer, Thompson disputed the $269,120.58 balance shown on his invoice, which consisted of the $219,000 Thompson had borrowed plus interest, stating that he had no idea where the 269 number comes from and that he borrowed $110,000.

Thompson made similar statements in a later call with FDIC contractors.

Thompson was later charged with violating 18 USC Section 1 14, which prohibits knowingly making any false statement to influence the FDIC's action on any loan.

A jury found Thompson guilty and he moved for acquittal, arguing that his statements were not false because he had in fact borrowed $110,000 even though he later borrowed more.

The courts below concluded that they did not need to reach that argument because they read section 1014 to also criminalize misleading statements, and Thompson's statements were at least misleading.

Held section 1014, which prohibits knowingly making any false statement, does not criminalize statements that are misleading but but not false.

Pages 4 to 10A.

The statutory text criminalizes false statements but does not use the word misleading.

False and misleading are two different things.

A misleading statement can be true and a true statement is not false.

Given that, it is significant that the statute uses only the word false, which means not true, adding any before false statement does not transform the scope of the statute.

A statute that applies to any false statement does not cover all misleading statements, only the false ones.

While the government argues that false and misleading have long been considered synonyms, the overlap between false statements and misleading ones is beside the point.

The only relevant question under the text of section 1014 is whether the statement, even if misleading, deceitful, or some other adjective, is Also false.

Pages 4 to 6B.

Statutory context confirms that section 1014 does not cover all misleading statements many other statutes, including other criminal statutes in Title 18, expressly prohibit both false and misleading statements.

Interpreting false in section 1014 to include misleading would make the inclusion of misleading in those statutes superfluous.

Further, when Section 1014 was enacted in 1948, none of the 11 predecessor provisions consolidated into Section 1014 use the word misleading, while many other statutes from the same period use the phrase false or misleading.

Historical context thus confirms that when Congress intended to cover all misleading statements, it knew how to do so.

Custis v.

United States, 511 U.S.

485, 492 pages 6, 7C.

Precedent supports the Court's reading of section 1014.

In United States v.

Wells, 519 U.S.

482, the Court held that section 1014 does not incorporate a materiality requirement because the statute does not so much as mention materiality, whereas many other statutes do.

Ed.

At 490.

492 the same logic suggests that section 1014 does not reach all misleading statements.

In Williams vs.

United States, 458 U.S.

279, the Court reversed a conviction under section 114 for depositing several bad checks on the basis that the defendant's conduct did not involve the making of a false statement because a check is not a factual assertion at all and therefore cannot be characterized as true or false.

At 284.

That logic shows that a conviction under section 1014 requires at least two things.

1.

The defendant made a statement and 2 that statement can be characterized as false and not true.

Section 1014 does not cover a statement rendered misleading by virtue of a material omission unless that statement can be characterized as false and not true.

Finally, the Court's Decision in K vs United States, 303US 1, does not support the government as K did not suggest that misleading statements were independently unlawful under section 1014's predecessor.

Pages 7 to 9D.

The right question under section 1014 is whether Thompson's statements were false, and the Court agrees that at least some context is relevant to that determination.

The Court remands for the 7th Circuit to determine whether a reasonable jury could find that Thompson's statements were false.

Pages 9 to 1089 F.4th 1010 vacated and remanded.

Justice Alito Concurring Opinion I join the opinion of the Court but write separately to summarize my understanding of the decision.

Five aspects of today's decision are most important.

First, Section 1014 criminalizes only false statements, and Congress's omission of misleading from the statute was intentional, making the Seventh Circuit's interpretation erroneous second, false in Section 1014 carries its ordinary meaning of not true as supported by dictionary definitions and the parties positions.

Third, statements must be evaluated for falsity within their full context, not in isolation, as demonstrated through examples of statements that may be literally true but false in context, like a child saying I ate three cookies when they ate 12, or literally false but true in context, like an ironic statement about a teenager's helpfulness with chores.

Fourth, while false and misleading may overlap in ordinary speech, courts should avoid any reference to misleading statements in section 1014 cases as there is no clear line between contextually false and merely misleading statements.

The current pattern jury instructions appropriately focus only on falsity.

Fifth, the remand question is narrow.

Using the sufficiency of evidence standard, the 7th Circuit must determine whether any rational finder of fact could conclude beyond a reasonable doubt that Thompson's statements were false in context, as the jury was not instructed about misleading statements and Thompson challenges only the sufficiency of evidence.

With these observations, I join the Court's opinion.

Justice Jackson Concurring Opinion I agree with the Court's conclusion that 18 USC Section 1014 criminalizes only false statements.

I write separately to note that the pre verdict instructions the district court provided to the jury in this case did not say otherwise.

The jury received correct instructions requiring proof beyond a reasonable doubt that Thompson made the charged false statements and was not advised about the Seventh Circuit's erroneous misleading representations standard.

For count two, the jury specifically found Thompson made all alleged statements.

In my view, little remains for the 7th Circuit to do on remand except affirm the district court's judgment upholding the jury's guilty verdict.

The jury has already determined whether Thompson's statements were false, and at most the 7th Circuit can assess whether any reasonable jury could have found Thompson's statements satisfied Section1014's falsity element, a legal issue Justice Jackson believes is not subject to reasonable debate.

Case Implications Based on the Court's ruling and the concurring opinions, this decision may have real world implications for federal prosecutors, defense attorneys, and regulated entities dealing with the FDIC and other federal agencies.

The Court's bright line distinction between false and misleading statements under section 1014 and may make prosecutions more challenging as prosecutors must now prove actual falsity rather than mere deception through omission or misleading implications.

This may particularly impact cases involving complex financial transactions or partial disclosures where statements might be technically true but create misleading impressions.

However, Justice Alito's concurrence provides important practical guidance by emphasizing that falsity must be evaluated in context, allowing prosecutors to argue that literally true statements can still be false when their contextual meaning is untrue.

This balanced approach means that while prosecutors lose the ability to charge purely misleading statements under section 1014, they retain the ability to prosecute statements that are false when viewed in their full context.

For financial institutions and their customers, the ruling provides clearer boundaries around criminal liability for communications with federal regulators, though it simultaneously highlights the importance of considering how statements might be interpreted in their full context rather than focusing solely on literal truth.