Kyle Syphax v. United States

This Court has stressed “[t]he rule of lenity requires ambiguous criminal laws to be interpreted in favor of the defendants subjected to them.” United States v. Santos, 553 U.S. 507, 514 (2008) (plurality op.). Normally, a mere “division of judicial authority” over a provision’s meaning does not trigger the rule. Reno v. Koray, 515 U.S. 50, 64-65 (1995) (quoting Moskal v. United States, 498 U.S. 103, 108 (1990)). Rather, this rule applies “if at the end of the process of construing what Congress has expressed, there is a grievous ambiguity or uncertainty in the statute[.]” Shaw v. United States, 580 U.S. 63, 71 (2016) (citations omitted). The question presented is: When Circuits split over a penal provision’s meaning, with each side believing that its competing, rational interpretation is compelled by the provision’s plain text, does the nature of that disagreement signal inherent ambiguity that triggers the rule of lenity?