Bittner v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Bittner v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Bittner v. United States.
The Supreme Court decided in Bittner v. United States that the Bank Secrecy Act's $10,000 maximum penalty for nonwillful violations applies on a per-report basis, not per-account. Alexandru Bittner, a dual citizen, was initially fined $2.72 million for late reports involving multiple accounts. The Court reversed the Fifth Circuit's decision, emphasizing that penalties for nonwillful violations should be calculated per report filed.
Holding
The single most important “bottom line” of what the Court decided in Bittner v. United States.
The Court held that the BSA's $10,000 maximum penalty for nonwillful violations accrues on a per-report basis, not a per-account basis.
Constitutional Concepts
These are the Constitution-related themes that appear in Bittner v. United States. Click a concept to see other cases that involve the same idea.
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Why Administrative Law is relevant to Bittner v. United States
The case involves the interpretation of statutory provisions and the limits of agency authority in imposing penalties.
Syllabus excerpt (verbatim)The Court begins with the terms of the most immediately relevant statutory provisions—31 U. S. C. § 5314, which delineates an individual's legal duties under the BSA, and § 5321, which outlines the penalties that follow for failing to discharge those duties.
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Why Void for Vagueness is relevant to Bittner v. United States
The Court addresses the clarity of statutory language regarding penalties, which impacts fair notice and consistent enforcement.
Syllabus excerpt (verbatim)The government's interpretation defies a traditional rule of statutory construction: When Congress includes particular language in one section of a statute and omits it from a neighbor, the Court normally understands that difference in language to convey a difference in meaning.
Key Quotes
Short excerpts from the syllabus in Bittner v. United States that support the summary and concepts above.
The BSA's $10,000 maximum penalty for the nonwillful failure to file a compliant report accrues on a per-report, not a per-account, basis.
The statute does not speak of accounts or their number but rather the legal duty to file reports.
The government's per-account penalty reading invites anomalies.