Percoco v. United States
Citation
598 U.S. 319 (2023)
Facts
Stub — to be completed.
Issue
Stub — to be completed.
Holding
Stub — to be completed.
Rule
The honest services fraud statute, 18 U.S.C. § 1346, does not extend to private individuals unless they owed a fiduciary duty to the public at the time of the alleged fraud.
Significance
Limited the scope of § 1346 by holding that a private citizen — even one with significant informal influence over government — cannot be convicted of honest services fraud absent a cognizable fiduciary duty to the public, curbing prosecutorial overreach.