United States v. Santos — Alito, J., Dissenting

Summary

The plurality held that 'proceeds' in the money laundering statute means 'profits' rather than 'receipts,' applying the rule of lenity to resolve statutory ambiguity. This interpretation avoids a merger problem where ordinary business expenses of an illegal activity would constitute money laundering. Justice Stevens concurred in the judgment, arguing the definition may vary by predicate offense, while Justices Alito and Breyer dissented, contending 'proceeds' means gross receipts.