2004 Supreme Court term

DAVID B. PASQUANTINO CARL J. PASQUANTINO, AND ARTHUR HILTS v. UNITED STATES OF AMERICA

Dockets 03-725Argued
AI-generated independent summary

This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.

In brief

Overview

The revenue rule is a longstanding principle that prevents U.S. courts from enforcing foreign laws that affect contracts.

Petitioners argue that the revenue rule bars both direct and indirect enforcement of foreign tax laws.

Background and question before the Court

According to Respondent, the prosecution alleges wire fraud that defrauded a foreign government of tax revenue.

What each side argues

Petitioner Position

Petitioners argue that the revenue rule bars both direct and indirect enforcement of foreign tax laws.

Respondent Position

The United States argues that restitution under the mandatory statute should be ordered and does not violate the revenue rule.

According to United States, absent clear congressional intent to override the revenue rule, statutes should not be interpreted to contravene it.

According to United States, there is no obligation for the United States to assist a foreign sovereign in enforcing its tax laws.

According to Respondent, prosecuting wire fraud serves United States interests independent of the foreign government's loss.

What happened at oral argument

Oral argument was held before the Supreme Court at 11:13 a.m.

What the Court decided

Pending This section will be added when the relevant Court material is available.

Why it matters

Source-limited The available primary sources do not support a complete explanation yet.

Terms to know

No glossary terms are available for this guide.

Primary sources

Read the source materials on the official site or open the immutable repository copy used for this guide.

  • 83b90ef958dcab72e894-r1-1108b87382a89de1.pdforal argument transcript

Guide generated September 20, 2026. Automated validation accepted this version.