Opinion of the Court
title Congress chose is among those terms. Even the Government acknowledged that if the terms in §1028A(a)(1) are unclear, “the title is a useful clue.” Tr. of Oral Arg. 80.
Two additional points bolster this approach. First, the title here is not serving the unenviable role of pithily summarizing a list of “complicated and prolific” provisions. Trainmen, 331 U. S., at 528. Section 1028A is a focused, standalone provision. Second, a title is “especially valuable [where] it reinforces what the text’s nouns and verbs independently suggest.” Yates v. United States, 574 U. S. 528, 552 (2015) (Alito, J., concurring in judgment). As explained below, §1028A(a)(1)’s text independently suggests a focus on identity theft. See infra, at 12–15.
Indeed, this Court has already once used §1028A’s title and place in the statutory scheme to shed light on its text. In Flores-Figueroa v. United States, 556 U. S. 646 (2009), this Court pointed out that a neighboring provision, §1028, carries the broad title “ ‘Fraud and related activity in connection with identification documents, authentication features, and information.’ ” Id., at 655. Section 1028A, in contrast, is far more targeted, “us[ing] the words ‘identity theft.’ ” Ibid. That “Congress separated the [identity] fraud crime from the [identity] theft crime in” §1028A suggests that §1028A is focused on identity theft specifically, rather than all fraud involving means of identification. Ibid.[1]
Given that, it is abundantly clear why the Government urges the Court to ignore the title. The Government’s broad reading, covering any time another person’s means of identification is employed in a way that facilitates a crime,
- ↑ Flores-Figueroa held that under §1028A(a)(1) a defendant must know “that the ‘means of identification’ he or she unlawfully transferred, possessed, or used, in fact, belonged to ‘another person.’ ” 556 U. S., at 647. The Court not only looked to §1028A(a)(1)’s theft-focused title and role in the statutory structure, but also drew on an understanding that the provision covers “classic identity theft.” Id., at 655–656.
