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Honest Services After Skilling: Judicial, Prosecutorial And Legislative Responses, Iris E. Bennett, Jessie K. Liu, Cynthia J. Robertson, Govind C. Persad
Honest Services After Skilling: Judicial, Prosecutorial And Legislative Responses, Iris E. Bennett, Jessie K. Liu, Cynthia J. Robertson, Govind C. Persad
Sturm College of Law: Faculty Scholarship
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.