Mad Libs, Dr. Seuss and Limiting the Reach of
Sarbanes-Oxley
The U.S. Supreme Court in Yates v. United States limited the
reach of 18 U.S.C. §1519 -- part of the Sarbanes-Oxley Act of
2002 -- by interpreting the term "tangible objects" in
that statute to include only such objects that relate to records or
record keeping. In Yates, a commercial fisherman's ship had
been boarded by federal authorities who were checking to ensure
that no red groupers that were too small had been caught and kept.
Unfortunately for the fishermen, the authorities found some
too-small fish, asked that they be segregated in a box, and told
the captain to meet up back at port. Once there, the fish were
gone. A crew member told the authorities that the captain, John
Yates, told him to pitch the contraband fish over the side. The
government charged Yates with violating §1519, which calls for
up to 20 years in prison for one who "knowingly alters,
destroys, mutilates, conceals, covers up,
