US v.
Santos, 128 S. Ct. 2020 - Supreme Court 2008
The rule of lenity
[P]enal statutes must be construed to reach no further than their words; no person can be made subject to them by
implication.'[Citation - in People v. Cornett, Cal: Court of Appeal, 1st Appellate Dist., 2nd Div. 2010] From the face of the statute, there is no more reason to think that "proceeds" means "receipts" than there is to think that "proceeds" means "profits." Under a long line of our decisions, the tie must go to the defendant. The rule of lenity requires ambiguous criminal laws to be interpreted in favor of the defendants
subjected to them. See United States v. Gradwell, 243 U.S. 476, 485, 37 S.Ct. 407, 61 L.Ed. 857 (1917); McBoyle v. United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931);United States v. Bass, 404 U.S. 336, 347-349, 92 S.Ct. 515, 30 L.Ed.2d 488 (1971).
This venerable rule not only vindicates the fundamental principle that no citizen should be held accountable for a violation of a statute whose commands are uncertain, or subjected to punishment that is not clearly prescribed. It also places the weight of inertia upon the party that can best induce Congress to speak more clearly and keeps courts from making criminal law in Congress's stead. Because the "profits" definition of "proceeds"
is always more defendant-friendly than the "receipts" definition, the rule of lenity dictates that it should be adopted.
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