Bittner v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Bittner v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Bittner v. United States.
The Supreme Court addressed the interpretation of the Bank Secrecy Act's penalty provisions for nonwillful violations. Alexandru Bittner was penalized $2.72 million for late-filed reports involving multiple foreign accounts. The Court concluded that the $10,000 maximum penalty applies per report, not per account.
Holding
The single most important “bottom line” of what the Court decided in Bittner v. United States.
The Court held that the BSA's $10,000 maximum penalty for nonwillful violations accrues on a per-report, not a per-account, basis.
Constitutional Concepts
These are the Constitution-related themes that appear in Bittner v. United States. Click a concept to see other cases that involve the same idea.
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Why Administrative Law is relevant to Bittner v. United States
The case involves the interpretation of statutory provisions and the limits of agency authority in imposing penalties.
Syllabus excerpt (verbatim)The Court begins with the terms of the most immediately relevant statutory provisions—31 U. S. C. § 5314, which delineates an individual's legal duties under the BSA, and § 5321, which outlines the penalties that follow for failing to discharge those duties.
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Why Excessive Fines is relevant to Bittner v. United States
The case addresses the issue of whether the penalties imposed are excessive under the statutory framework.
Syllabus excerpt (verbatim)The BSA's $10,000 maximum penalty for the nonwillful failure to file a compliant report accrues on a per-report, not a per-account, basis.
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Why Procedural Due Process is relevant to Bittner v. United States
The case involves the fairness of the penalty process and the interpretation of statutory requirements.
Syllabus excerpt (verbatim)The government neither contested the accuracy of Bittner's new filings nor suggested that Bittner's previous errors were willful.
Key Quotes
Short excerpts from the syllabus in Bittner v. United States that support the summary and concepts above.
The BSA's $10,000 maximum penalty for the nonwillful failure to fle a compliant report accrues on a per-report, not a per-account, basis.
Section 5321 authorizes the Secretary to impose a civil penalty of up to $10,000 for 'any violation' of § 5314.
Congress did not say that the government may impose nonwillful penalties on a per-account basis.
