Neder v. United States

Petitioner was tried on charges of violating a number of federal criminal statutes penalizing fraud. It is agreed that the District Court erred in refusing to submit the issue of materiality to the jury with respect to those charges involving tax fraud. See United States v. Gaudin, 515 U. S. 506 (1995). We hold that the harmless-error rule of Chapman v. California, 386 U. S. 18 (1967), applies to this error. We also hold that materiality is an element of the federal mail fraud, wire fraud, and bank fraud statutes under which petitioner was also charged.

I

In the mid-1980’s, petitioner Ellis E.…