Tenth Circuit expands the reach of the wire fraud statute to encompass a web site accessed and hosted from different states, which was used to disseminate fraudulent claims about a defendant’s unlicensed law practice.
The Eighth Circuit has set a particularly low bar for the government to hurdle in proving mail fraud, by holding that even routine discovery requests in a civil case qualify as mailings “in furtherance” of a scheme largely accomplished prior to the filing of that action.
A consultant assisting local schools in obtaining federally-distributed funds intended to facilitate Internet connectivity at the schools was charged with defrauding the program, even though the funding applications which she prepared did not violate any of the regulations of the program. The jury rejected this defense and so, on appeal, did the Ninth Circuit. United… Continue Reading
The Ninth Circuit recently reversed wire fraud convictions on the ground that the wire transfers upon which the 18 U.S.C. § 1343 charges were based occurred so long after the underlying activity was completed that the transfers could not be said to be "in furtherance" of a fraud. United States v. Lazarenko, No. 06-10592 (9th… Continue Reading