Bittner v. United States

Summary

The Court held that the Bank Secrecy Act’s maximum $10,000 penalty for nonwillful reporting violations applies per deficient annual report, not per unreported account, and reversed and remanded the Fifth Circuit’s judgment. Justice Gorsuch’s majority opinion, joined by Chief Justice Roberts and Justices Alito, Kavanaugh, and Jackson, relied on statutory text, differences between the nonwillful and willful penalty provisions, and contextual evidence. In Part II–C, joined only by Justice Jackson, Justice Gorsuch additionally invoked the rule of lenity. Justice Barrett dissented, joined by Justices Thomas, Sotomayor, and Kagan, reasoning that the statute and regulations impose account-specific reporting obligations and permit a separate penalty for each unreported account.