Section 1028A(a)(1) would thus apply automatically any time a name or other means of identification happens to be part of the payment or billing method used in the commission of a long list of predicate offenses. Dubin’s more targeted reading requires that the use of a means of identification have “a genuine nexus” to the predicate offense. When the underlying crime involves fraud or deceit, as many of §1028A’s predicates do, this entails using a means of identification specifically in a fraudulent or deceitful manner, not as a mere ancillary feature of a payment or billing method. A careful examination of §1028A(a)(1)’s text and structure points to a narrower reading. Pp. 4–5.
(b) The terms “uses” and “in relation to” have been singled out by this Court as being particularly sensitive to context. The “various definitions of ‘use’ imply action and implementation.” Bailey v. United States, 516 U. S. 137, 145. Beyond that general concept, however, “ ‘use’ takes on different meanings depending on context.” Id., at 143. This requires looking “not only to the word itself, but also to the statute and the [surrounding] scheme, to determine the meaning Congress intended.” Ibid. “In relation to” is similarly context sensitive. If extended to its furthest reach, “relate to” would be practically limitless. The phrase clearly refers to a relationship or nexus of some kind, but the nature and strength of this relationship or nexus will be informed by context. Because the presence of two such context-dependent terms renders §1028A(a)(1) doubly attuned to its surroundings, resort to context is especially necessary. Pp. 5–7.
(c) Section 1028A(a)(1)’s title and terms both point toward reading the provision to capture the ordinary understanding of identity theft, where misuse of a means of identification is at the crux of the criminality. Pp. 8–15.
(1) Section 1028A is a focused, standalone provision, and its title—“Aggravated identity theft”—suggests that identity theft is at the core of §1028A(a)(1). A statute’s title has long been considered a “ ‘too[l] available for the resolution of a doubt’ about the meaning of a statute.” Almendarez-Torres v. United States, 523 U. S. 224, 234. Section 1028A’s title is especially valuable here because it does not summarize a list of “complicated and prolific” provisions, Trainmen v. Baltimore & Ohio R. Co., 331 U. S. 519, 528, and also “reinforces what the text’s nouns and verbs independently suggest,” Yates v. United States, 574 U. S. 528, 552 (Alito, J., concurring in judgment). The Court has previously observed the contrast between §1028A’s targeted title and the broad title of neighboring provision §1028: “ ‘Fraud and related activity in connection with identification documents, authentication features, and information.’ ” Flores-Figueroa v. United States, 556 U. S. 646, 655. That “Congress separated the [identity] fraud crime from the [identity] theft crime in” §1028A suggests that §1028A is focused on
