The Holding in United States v. Santos

The Supreme Court held that proceeds under 18 U.S.C. § 1956 means profits rather than gross receipts, a construction reached in United States v. Santos.

The Merger Problem

Justice Stevens' concurrence weighs the merger problem under the federal money-laundering statute.

The Rule of Lenity

The Court's analysis considers the rule of lenity when the statute is ambiguous.

Significance for the Statute

The decision constrains the reach of the money-laundering statute in federal prosecutions.

Reading the Opinion

The opinion turns on statutory text and congressional purpose.

Research Note

This digest is general research material, not legal advice.

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