The federal honest services statute is one sentence long. The law has a long reach, however. It is designed to apply to all frauds within the same chapter in the federal criminal code, so mail fraud, wire fraud, bank fraud, health care fraud (enacted as part of HIPAA), securities fraud (enacted as part of Sarbanes-Oxley Act), and conspiracies and attempts to commit any of those crimes. Because of its short sentence and broad application, the former CEO of Enron, Jeffrey Skilling, challenged the constitutionality of the law. What happened in the
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