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DUBIN v. UNITED STATES

Opinion of the Court

Time and again, this Court has prudently avoided reading incongruous breadth into opaque language in criminal statutes. In Van Buren v. United States, 593 U. S. ___ (2021), the “far-reaching consequences” of the Government’s reading “underscore[d] the implausibility of the Government’s interpretation.” Id., at ___ (slip op., at 17). In Marinello, the Court rejected the Government’s reading of a statute about obstructing administration of the Tax Code that would have swept in the “person who pays a babysitter $41 per week in cash without withholding taxes,” as well as someone who “leaves a large cash tip in a restaurant, fails to keep donation receipts from every charity to which he or she contributes, or fails to provide every record to an accountant.” 584 U. S., at ___ (slip op., at 7). Nor was all such conduct innocent, as the statute required an individual to act “ ‘corruptly.’ ” Id., at ___ (slip op., at 8). Even still, “[h]ad Congress intended” to sweep so far, “it would have spoken with more clarity than it did.” Id., at ___ (slip op., at 7). In Yates, the Court held that the Government’s “unrestrained” reading would have turned a provision focused on “records” and “documents” into “an all-encompassing ban on the spoliation of evidence” that would “sweep within its reach physical objects of every kind,” including a fish. 574 U. S., at 536, 540 (plurality opinion). Had Congress set out to do so, “one would have expected a clearer indication of that intent.” Ibid.

So too here. The Government’s reading would sweep in the hour-inflating lawyer, the steak-switching waiter, the building contractor who tacks an extra $10 onto the price of the paint he purchased. So long as they used various common billing methods, they would all be subject to a mandatory two years in federal prison. To say that such a result