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United States v. Santos

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United States v. Santos
Seal of the United States Supreme Court.svg
Argued October 3, 2007
Decided June 2, 2008
Full case nameUnited States v. Santos
Citations553 U.S. 507 ( more )
Holding
The rule of lenity requires that the federal money-laundering statute's use of the inherently-ambiguous term "proceeds" be read in the light favorable to the accused. Here, that means it includes "profit" and not "receipts."
Court membership
Chief Justice
John Roberts
Associate Justices
John P. Stevens  · Antonin Scalia
Anthony Kennedy  · David Souter
Clarence Thomas  · Ruth Bader Ginsburg
Stephen Breyer  · Samuel Alito
Case opinions
PluralityScalia, joined by Souter, Ginsburg; Thomas (not Part IV)
ConcurrenceStevens (in judgment)
DissentBreyer
DissentAlito, joined by Roberts, Kennedy, Breyer

United States v. Santos, 553 U.S. 507(2008), was a United States Supreme Court case in which the court held that the rule of lenity requires that the federal money-laundering statute's use of the inherently-ambiguous term "proceeds" be read in the light favorable to the accused. Here, that means it includes criminal "profit" and not criminal "receipts." [1] [2]

Contents

Background

In an illegal lottery run by Santos (the first defendant), runners took commissions from the bets they gathered, and some of the rest of the money was paid as salary to Diaz (the second defendant) and other collectors and to the winning gamblers. Based on these payments to runners, collectors, and winners, Santos was convicted of, among other things, violating the federal money-laundering statute, 18 U.S.C. §1956, which prohibits the use of the "proceeds" of criminal activities for various purposes, including engaging in, and conspiring to engage in, transactions intended to promote the carrying on of unlawful activity. Based on his receipt of salary, Diaz pleaded guilty to conspiracy to launder money. The Seventh Circuit Court of Appeal affirmed the convictions. [1]

On collateral review, the federal District Court ruled that, under intervening Circuit precedent interpreting the word "proceeds" in the federal money-laundering statute, it applies only to transactions involving criminal profits, not criminal receipts. Finding no evidence that the transactions on which respondents' money-laundering convictions were based involved lottery profits, the court vacated those convictions. The Seventh Circuit affirmed. [1]

Opinion of the court

The Supreme Court heard oral arguments on October 3, 2007. It issued an opinion on June 2, 2008. [1] Commentators thought the period of time between the arguments and the opinion was notably long, especially because cases that were expected to be more contentious (such as Medellín v. Texas ) came much earlier. [2]

Later developments

References

  1. 1 2 3 4 United States v. Santos, 553 U.S. 507 (2008).
  2. 1 2 "Opinion Recap: US v. Santos". SCOTUSblog. June 7, 2008. Retrieved January 27, 2026.

This article incorporates written opinion of a United States federal court. As a work of the U.S. federal government, the text is in the public domain .


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