Document Type
Article
Publication
Criminal Litigation
Year
2010
Citation Information
Govind Persad, Jessie K. Liu, Cynthia J. Robertson, and Govind C. Persad, Honest Services after Skilling: Judicial, Prosecutorial and Legislative Responses, 11 1 (2010), available at https://scholar.law.colorado.edu/faculty-articles/2057.
Abstract
In Skilling v. United States, the U.S. Supreme Court substantially narrowed the reach of the “honest services fraud” statute, 18 U.S.C. § 1346, by holding that it applies only to “bribery and kickback schemes,” not to “undisclosed self-dealing by a public official or private employee.” Skilling v. United States, 130 S. Ct. 2896 (2010). Two companion cases also were decided the same day. See Black v. United States, 130 S. Ct. 2963 (2010); Weyhrauch v. United States, 130 S. Ct. 2971 (2010). These decisions have major significance for federal fraud prosecutions.