Thompson v. United States (Criminal / False Statement)

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In Thompson v. United States the Supreme Court held that 18 U.S.C. §1014, which prohibits “knowingly mak[ing] any false statement” to influence the FDIC’s actions on a loan, does not extend to statements that are merely misleading but not technically false.

Patrick Thompson, a former Chicago Alderman, was charged under §1014 after disputing his loan balance in conversations with FDIC contractors, stating he had only borrowed $110,000 when in fact he had borrowed $219,000 in total. A jury convicted him, and the lower courts upheld the conviction on the basis that his statements, though potentially technically true, were misleading. They concluded §1014 criminalizes misleading statements.

The Supreme Court reversed, emphasizing that the statute's text criminalizes only “false” statements—not misleading ones. The Court distinguished between the two, noting that misleading statements can be true, and true statements are not false. Because Congress included only the word “false,” and not “misleading,” the Court concluded the statute’s reach does not extend beyond literal falsehoods.

Contextual analysis reinforced this conclusion. Other statutes in Title 18 use both terms explicitly. The historical and legislative context showed that Congress knew how to include “misleading” when it intended to do so, and declined to do so in §1014. Precedents like United States v. Wells and Williams v. United States also supported a narrow interpretation of §1014, requiring statements that are actually and factually false.

The Court remanded the case for the Seventh Circuit to decide whether a reasonable jury could find that Thompson’s statements were, in fact, false—not merely misleading.

Chief Justice Roberts delivered the opinion for a unanimous Court. Justices Alito and Jackson filed concurring opinions.