Fischer v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Fischer 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 Fischer v. United States.
The Supreme Court in Fischer v. United States addressed the scope of 18 U.S.C. § 1512(c)(2), determining whether it covers all forms of obstructive conduct or is limited by § 1512(c)(1). The Court concluded that § 1512(c)(2) is limited to acts impairing the availability or integrity of records, documents, or objects used in official proceedings. This interpretation aligns with the legislative intent to close specific loopholes without creating a broad catchall provision.
Holding
The single most important “bottom line” of what the Court decided in Fischer v. United States.
The Court held that to prove a violation of § 1512(c)(2), the government must establish impairment of the availability or integrity of records, documents, or objects used in an official proceeding.
Constitutional Concepts
These are the Constitution-related themes that appear in Fischer v. United States. Click a concept to see other cases that involve the same idea.
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Why Void for Vagueness is relevant to Fischer v. United States
The Court's analysis focused on interpreting the scope of the statute to avoid overly broad applications that could lead to arbitrary enforcement, which is a key concern of the void for vagueness doctrine.
Syllabus excerpt (verbatim)Our usual approach in obstruction cases has been to 'resist reading' particular sub-provisions 'to create a coverall' statute.
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Why Judicial Review is relevant to Fischer v. United States
The Court exercised its power of judicial review to interpret the statute and determine its proper scope, ensuring it aligns with legislative intent and constitutional principles.
Syllabus excerpt (verbatim)To prove a violation of Section 1512(c)(2), the Government must establish that the defendant impaired the availability or integrity for use in an official proceeding of records, documents, objects, or other things used in the proceeding, or attempted to do so.
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Why Substantive Due Process is relevant to Fischer v. United States
The Court's interpretation of the statute reflects concerns about fair notice and preventing arbitrary enforcement, which are substantive due process considerations.
Syllabus excerpt (verbatim)Given that subsection (c)(2) was enacted to address the Enron disaster, not some further fung set of dangers, it is unlikely that Congress responded with such an unfocused and 'grossly incommensurate patch.'
Key Quotes
Short excerpts from the syllabus in Fischer v. United States that support the summary and concepts above.
The Government must establish that the defendant impaired the availability or integrity for use in an official proceeding.
The Sarbanes-Oxley Act of 2002 imposes criminal liability on anyone who corruptly 'alters, destroys, mutilates, or conceals a record, document, or other object.'
The 'otherwise' provision of § 1512(c)(2) is limited by the list of specific criminal violations that precede it in (c)(1).
