Thompson v. United States is a 2025 decision of the United States Supreme Court that clarified the scope of criminal liability under 18 U.S.C. § 1014. The case addressed whether a person can be convicted for making a statement to the Federal Deposit Insurance Corporation (FDIC) that is misleading but technically true.
The Court unanimously held that the statute requires proof that a statement is actually false, not merely misleading. This decision reaffirmed the importance of precise statutory language in criminal prosecutions and emphasized that courts must not expand criminal liability beyond what Congress has clearly written into law.
Background and Statutory Framework of Thompson v. United States
The FDIC is a federal agency responsible for insuring bank deposits and managing the resolution of failed banks. When banks fail, the FDIC often steps in to collect outstanding loan balances owed to those institutions. In carrying out this role, the FDIC relies on information provided by borrowers and other individuals.
The statute at the center of the dispute, 18 U.S.C. § 1014, makes it a crime to “knowingly make any false statement or report” for the purpose of influencing certain federal agencies and financial institutions, including the FDIC. The statutory text uses the word “false” but does not include the word “misleading.” This distinction became central to the dispute in Thompson v. United States.
Facts of Thompson v. United States Case
Between 2011 and 2014, Patrick Daley Thompson obtained three loans from the Washington Federal Bank for Savings. The loans totaled $219,000. The first loan, issued in 2011, was for $110,000. Two additional loans followed: $20,000 in 2013 and $89,000 in 2014.
In 2017, the Washington Federal Bank for Savings failed. After the bank’s failure, the FDIC sought to collect the outstanding balance on Thompson’s loans, including accrued interest. The FDIC invoiced Thompson for $269,120.58, which reflected the principal amounts and interest due.
Thompson disputed the amount demanded by the FDIC. During communications with FDIC contractors, he stated that he had borrowed $110,000 and challenged the accuracy of any higher amount. In one instance, he indicated that the $110,000 loan was for home improvement. These statements did not explicitly deny the existence of the other loans but did not mention them either.
Procedural History
The federal government charged Thompson with two counts of violating 18 U.S.C. § 1014, alleging that he knowingly made false statements to the FDIC. The prosecution argued that Thompson falsely stated that he owed only $110,000 and that the funds were for home improvement, despite knowing that he had received a total of $219,000 and that the $110,000 loan was paid to a law firm as a capital contribution.
At trial, Thompson moved for acquittal, arguing that his statements were technically true and, at most, misleading by omission. He contended that § 1014 criminalizes only false statements and does not extend to statements that are merely misleading. The district court denied his motion, and the jury returned a guilty verdict.
Thompson appealed, and the United States Court of Appeals for the Seventh Circuit affirmed the conviction. The Seventh Circuit concluded that misleading statements could fall within the scope of § 1014. This interpretation set the stage for Supreme Court review in Thompson v. United States.
Issues Before the Supreme Court
The primary issue before the Supreme Court was whether 18 U.S.C. § 1014 permits criminal prosecution for statements that are misleading but not false. More specifically, the Court considered whether a statement that is technically true but omits relevant information can satisfy the statute’s requirement of a “false statement.”
Thompson v. United States Judgment
The Supreme Court in Thompson v. United States unanimously reversed the judgment of the Seventh Circuit. Writing for the Court, Chief Justice John Roberts held that § 1014 requires the government to prove that a defendant made a false statement, not merely a misleading one.
The Court emphasized that statutory interpretation begins with the text of the statute. Section 1014 uses the word “false” and does not include “misleading.” The Court observed that Congress has, in other statutes, used the phrase “false or misleading” when it intended to prohibit both types of statements. The absence of the word “misleading” in § 1014 was therefore significant.
The Court also reviewed the historical development of § 1014 and its statutory precursors. It noted that all eleven predecessor statutes similarly used language focused on falsity and did not include misleading statements. This consistent drafting pattern supported the conclusion that Congress intentionally limited the statute’s reach.
Based on this analysis, the Court concluded that truthful but misleading statements fall outside the scope of § 1014. Because the lower courts had not made a determination that Thompson’s statements were actually false, the conviction could not stand. The Court therefore reversed and remanded the case for further proceedings consistent with its interpretation.
Concurring Opinions
Although the Court was unanimous in its judgment, two Justices wrote separate concurring opinions in Thompson v. United States.
Justice Ketanji Brown Jackson emphasized that the jury instructions in the district court did not include the word “misleading” and instead focused on falsity. She noted that the jury had been instructed under the correct legal standard. In her view, this raised questions about whether the conviction might still be upheld on remand based on the jury’s findings.
Justice Samuel Alito also wrote separately to underscore the importance of context in evaluating whether a statement is false. He cautioned that courts should not analyze statements in isolation but should consider how an ordinary listener would understand them in the full factual setting. Justice Alito suggested that the Seventh Circuit should reassess whether the evidence was sufficient to support a conviction under the correct falsity standard.
Conclusion
In Thompson v. United States, the Supreme Court unanimously held that 18 U.S.C. § 1014 applies only to false statements and does not reach statements that are merely misleading but true. By focusing closely on statutory text, legislative history, and established principles of criminal interpretation, the Court reaffirmed the importance of precision in criminal law. The decision clarifies the limits of federal false-statement prosecutions and stands as an important example of the judiciary’s role in enforcing the boundaries set by Congress.