United States v. John Anthony Williams

GRABER, Circuit Judge.

Defendant John Anthony Williams appeals his conviction and sentence for mail and wire fraud and money laundering. His main argument is that the government improperly charged him under an “intangible rights” theory of mail and wire fraud, because that theory does not apply to private individuals, and that the absence of a special verdict makes it impossible to determine whether the jury found “direct” fraud or “intangible rights” fraud. Since Congress passed 18 U.S.C. § 1346, we have not addressed directly whether the “intangible rights” theory applies to private-sector…