USA v. Thompson, No. 22-2254 (7th Cir. 2024)
Annotate this Case
In this case, the defendant, Patrick Thompson, was convicted of making false statements about his loans to financial institutions. Thompson took out three loans from a bank totaling $219,000. After the bank failed, its receiver, the Federal Deposit Insurance Corporation (FDIC), and a loan servicer, Planet Home, attempted to recoup the money owed by Thompson. However, Thompson disputed the loan balance, insisting that he had only borrowed $110,000. He was subsequently charged with and convicted of making false statements to influence the FDIC and a mortgage lending business, in violation of 18 U.S.C. § 1014.
On appeal, Thompson argued that his statements were not “false” under § 1014 because they were literally true, and that the jury lacked sufficient evidence to convict him. He also claimed that the government constructively amended the indictment and that the district court lacked the authority to order him to pay restitution to the FDIC.
The U.S. Court of Appeals for the Seventh Circuit rejected Thompson's arguments and affirmed the lower court's judgment. The court held that under its precedent, § 1014 criminalizes misleading representations, and Thompson's statements were misleading. The court also found that there was sufficient evidence to support Thompson's conviction and that the indictment was not constructively amended. Finally, the court held that the district court properly awarded restitution to the FDIC, as the FDIC had suffered a financial loss as a direct and proximate result of Thompson's false statements.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.