2017 Supreme Court term

CARL J. MARINELLO, II v. UNITED STATES

Dockets 16-1144Argued
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

Guide pending. Verified case metadata and available source documents are shown below while a supported explanation is prepared.

Background and question before the Court

According to Matthew S. Hellman, the case concerns how Congress defined the felony of obstructing the due administration of the tax code.

According to Matthew S. Hellman, the statute’s language was borrowed from a provision that prohibited obstruction of a pending proceeding, suggesting a narrow rather than all‑purpose tax crime.

The Court asked questions about the statutory context, the officer‑clause, and the Department’s prosecution policy.

What each side argues

Petitioner (Carl J. Marinello II) Position

According to Matthew S. Hellman, petitioner argues that the obstruction provision was not intended to create a broad tax crime but was modeled on a statute that barred obstruction of a pending proceeding.

According to Matthew S. Hellman, petitioner contends that the obstruction definition is broad, citing examples such as paying a gardener in cash, which is a predicate act in this case.

Respondent (United States) Position

Source-limited. The record does not yet support a complete account.

What happened at oral argument

Justice Sotomayor asked about the context in which the obstruction statute was drafted.

According to Justice Gorsuch, justice Gorsuch questioned whether the statute’s officer clause requires actual hindrance of an officer’s actions.

According to Justice Kagan, justice Kagan returned to the Department’s prosecution policy during questioning.

Justice Breyer asked whether the word “administration” in the statute is the operative term.

Justice Gorsuch followed up by asking if the statute’s heritage makes it preferable for certain reasons.

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.

  • a1d5cb32e8775920f290-r1-a78e13823ade6eb5.pdforal argument transcript

Guide generated September 26, 2026. Automated validation accepted this version.