Today (March 21, 2025) the U.S. Supreme Court unanimously ruled in favor of former Chicago Alderman Patrick Daley Thompson, overturning his convictions for violating 18 U. S. C. §1014 by making “false statement[s]” to the FDIC. Thompson, who served on Chicago’s city council from 2015 to 2022, was convicted in 2022 on charges of lying to federal bank regulators and filing false tax returns, leading to a four-month prison sentence.
The case centered on $219,000 Thompson received between 2011 and 2014 from Washington Federal Bank, which collapsed in 2017 amid fraud allegations. During the investigation, Thompson informed Federal Deposit Insurance Corporation (FDIC) representatives that he had borrowed $110,000 and possessed a promissory note for that amount, despite having received additional funds totaling $219,000.
The Court clarified that §1014 criminalizes only outright false statements, not those that are merely misleading. Chief Justice John Roberts, writing for the Court, emphasized that “false” and “misleading” are distinct terms, noting that a statement can be misleading yet still true. The Court remanded the case to reassess whether Thompson’s statements were indeed false under this interpretation.
This ruling makes the necessary proof to convict for §1014 violations closer to §1001 violations, which cannot be based solely on a true but misleading statement. 18 U. S. C. §1001 requires proof that the statement be materially false, fictitious, or fraudulent. Courts have consistently held that a statement that is literally true, even if misleading, does not meet the falsity requirement under §1001.
23-1095 Thompson v. United States (03/21/2025)
