United States v. Black
Citation
530 F.3d 596 (7th Cir. 2008)
Facts
Stub — to be completed.
Issue
Stub — to be completed.
Holding
Stub — to be completed.
Rule
Honest services fraud under 18 U.S.C. § 1346 requires that the alleged breach of fiduciary duty be material to the principal.
Significance
Seventh Circuit decision clarifying that materiality is an element of honest services fraud, reinforcing that minor or inconsequential breaches of duty cannot support a § 1346 conviction.