Harris Analyzes the Supreme Court’s Thompson v. United States 2025 Decision in the Legal Intelligencer  

05.05.2025

Stinson LLP Partner Reginald L. Harris authored a Legal Intelligencer article, "Supreme Court Decision Not as Broad-Sweeping as It Seems in 'Thompson v. United States,'" discussing how the Supreme Court’s recent decision in the matter clarifies the interpretation of the federal criminal statute 18 U.S.C. § 1014. The Court held that this statute applies only to false statements, not statements that are misleading but technically true.

In the matter, Patrick Thompson was convicted for stating that he borrowed $110,000 from a bank and omitting two additional loans, allegedly making a false statement to the FDIC. The Seventh Circuit upheld the conviction, which was later vacated by the Supreme Court, saying that since § 1014 does not explicitly contain the word "misleading," Thompson’s statements fell outside the statute’s scope.

"White-collar defendants facing prosecution for false statements under other federal criminal statutes undoubtedly will attempt to use the Thompson decision to undermine charges against them," Harris writes. "However, as the Court noted, § 1014 expressly only criminalizes ‘any false statement,’ whereas other criminal statutes targeting such statements are more expansive."

Harris advises that the Supreme Court’s Thompson decision is a cautionary tale for federal prosecutors, warning them to be careful not to read into criminal statutes what does not appear there. However, Harris maintains that the Thompson decision does not represent a significant shift in favor of white-collar defendants facing prosecution for potentially misleading statements.

Harris, a former federal prosecutor, provides strategic counsel and representation in internal investigations, corporate compliance matters, white collar criminal defense and civil trial litigation. He has significant courtroom experience, including trying over 20 federal criminal cases and arguing numerous appeals before the 8th Circuit Court of Appeals.

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