On June 24, 2010, the Supreme Court announced its decisions in three honest services fraud cases: Skilling v. United States, Black v. United States, and Weyrauch v. United States. The issues in these cases concerned the mail and wire fraud statutes, which make it a federal crime to use the mail or wires in furtherance of "any scheme or artifice to defraud." These cases also concern the honest services fraud statute, 18 U.S.C. § 1346, which reads as follows: "For the purposes of this chapter, the term, 'scheme or artifice to defraud' includes a scheme or artifice to deprive another of the intangible right of honest services."
To discuss the decisions, we have John Shu, who is an attorney at Stradling Yocca Carlson & Rauth.