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RATZLAF v. UNITED STATES

No. 92-1196.

510 U.S. 135 (1994)

RATZLAF ET UX. v. UNITED STATES

Supreme Court of United States.

Decided January 11, 1994.

Attorney(s) appearing for the Case

Stephen Robert LaCheen argued the cause for petitioners. With him on the briefs were Anne M. Dixon, Peter Goldberger, Pamela A. Wilk, James H. Feldman, Jr., Kevin O'Connell, and Christopher H. Kent.

Paul J. Larkin, Jr., argued the cause for the United States. On the brief were Solicitor General Days, Acting Assistant Attorney General Keeney, Deputy Solicitor General Bryson, John F. Manning, and Richard A. Friedman.*

GINSBURG, J., delivered the opinion of the Court, in which STEVENS, SCALIA, KENNEDY, and SOUTER, JJ., joined. BLACKMUN, J., filed a dissenting opinion, in which REHNQUIST, C. J., and O'CONNOR and THOMAS, JJ., joined, p. 150.

JUSTICE GINSBURG delivered the opinion of the Court.

Federal law requires banks and other financial institutions to file reports with the Secretary of the Treasury whenever they are involved in a cash transaction that exceeds $10,000. 31 U. S. C. § 5313; 31 CFR § 103.22(a) (1993). It is illegal to "structure" transactions—i. e., to break up a single transaction above the reporting threshold into two or more separate transactions—for...

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