## Facts

- John L. Yates captained a commercial fishing vessel in the Gulf of Mexico.
- In August 2007, an officer conducting an offshore inspection found red grouper that appeared below the 20-inch federal minimum size.
- The officer measured the catch, identified 72 undersized fish, separated them in crates, cited Yates, and instructed him to keep the fish segregated until return to port for seizure.
- While at sea, Yates directed his crew to throw the undersized fish overboard and replace them with larger fish.
- On return to port, only 69 fish in the crates measured undersized, and a crew member reported Yates’s disposal order.
- Federal prosecutors charged Yates, including under 18 U.S.C. § 1519 for knowingly destroying a “tangible object” to impede a federal investigation, alleging the fish were “tangible object[s].”

## Issues

1. Whether “tangible object” in 18 U.S.C. § 1519 includes any physical object, including fish, or is limited to objects used to record or preserve information.
2. Whether § 1519, enacted as part of Sarbanes–Oxley, applies to destruction of non-record physical evidence in a federal investigation.

## Decision

- The Supreme Court reversed Yates’s conviction under § 1519 by a 5–4 vote.
- A plurality concluded that, in § 1519, “tangible object” means an object used to record or preserve information and does not include fish.
- Justice Alito concurred in the judgment on narrower contextual grounds and provided the controlling rationale.
- The dissent would have affirmed, reading “tangible object” in its ordinary sense as any discrete thing with physical form.

## Legal Principles

- Statutory terms are construed in their specific and broader statutory context, not by dictionary breadth alone.
- Under noscitur a sociis, a general term following related specific terms may be limited by its associates; “tangible object” was read alongside “record” and “document.”
- Headings, placement within the U.S. Code, and statutory structure may inform meaning, though they are not dispositive.
- Where a criminal statute remains ambiguous after application of interpretive tools, the rule of lenity favors the narrower construction.

## Conclusion

The Court held that “tangible object” in 18 U.S.C. § 1519 refers to objects used to record or preserve information and does not cover fish, so discarding undersized grouper to prevent seizure could not support a § 1519 conviction.


Yates v. United States, 574 U.S. 528 (2015)