Opinion of the Court
that, names or other means of identification are used routinely for billing and payment, whether payment apps, credit and debit cards, a bill sent by mail, or an invoice sent electronically. So long as the criteria for the broad predicate offenses are met, the Government’s reading creates an automatic 2-year sentence for generic overbilling that happens to use ubiquitous payment methods.
A far more sensible conclusion from the statutory structure is that §1028A(a)(1)’s enhancement is not indiscriminate, but targets situations where the means of identification itself plays a key role—one that warrants a 2-year mandatory minimum. This points once more to a targeted reading, where the means of identification is at the crux of the underlying criminality, not an ancillary feature of billing.
E
If more were needed, a final clue comes from the staggering breadth of the Government’s reading. This Court has “ ‘traditionally exercised restraint in assessing the reach of a federal criminal statute.’ ” Marinello, 584 U. S., at ___ (slip op., at 9) (quoting United States v. Aguilar, 515 U. S. 593, 600 (1995)); see also Arthur Andersen LLP v. United States, 544 U. S. 696, 703–704 (2005); McBoyle v. United States, 283 U. S. 25, 27 (1931). This restraint arises “both out of deference to the prerogatives of Congress and out of concern that a fair warning should be given to the world in language that the common world will understan[d] of what the law intends to do if a certain line is passed.” Marinello, 584 U. S., at ___ (slip op., at 4) (internal quotation marks omitted). After all, “[c]rimes are supposed to be defined by the legislature, not by clever prosecutors riffing on equivocal language.” Spears, 729 F. 3d, at 758.
another element of the statute show that the Government itself understands the problems that arise from its sweeping reading of “uses” and “in relation to.”
