On March 21, the U.S. Supreme Court issued an opinion regarding the meaning of “false statement” in 18 U.S.C. § 1014 which defines terms for those who knowingly make a false statement or report. The case’s petitioner had taken out three loans totaling $219,000 from a bank that ended up failing, leaving the FDIC responsible for collecting the outstanding loans. During interactions with the FDIC’s loan servicer and contractors, the petitioner disputed the loan balance, claiming he borrowed only $110,000 — the amount of the first loan — after the FDIC’s servicer asserted that he owed over $260,000. The petitioner was found guilty by a jury of violating 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 Federal Deposit Insurance Corporation . . . upon any . . . loan.”

The 7th Circuit upheld the conviction, interpreting 18 U.S.C. § 1014 to criminalize misleading statements as well as false ones. The Supreme Court, however, held that 18 U.S.C. § 1014 does not criminalize statements that are misleading but not false. The Court emphasized that the statutory text specifically prohibits “false statements” and does not also prohibit “misleading” statements. The opinion highlighted the distinction between false and misleading statements, noting that a misleading statement can be true and that at least some misleading statements are not false. SCOTUS also considered statutory context and precedent, affirming that 18 U.S.C. § 1014 requires a statement to be false, not merely misleading.

The Supreme Court vacated the judgment of the 7th Circuit and remanded the case for further proceedings consistent with the opinion.