Ciminelli v. United States

The case centered on Louis Ciminelli, a Buffalo developer convicted for his role in a bid-rigging scheme related to New York's "Buffalo Billion" initiative. Ciminelli was found guilty of wire fraud under the "right to control" theory, which criminalizes schemes that deprive a victim of potentially valuable economic information necessary for discretionary decisions, even without intending to cause tangible economic loss. The Supreme Court reviewed the conviction and unanimously ruled that the federal wire fraud statute is limited to the protection of traditional property interests, explicitly rejecting the "right to control" theory as an invalid expansion of the law. The conviction was overturned because the government failed to prove an intent to defraud of money or property.

The Supreme Court ruled unanimously in favor of Ciminelli, vacating his conviction. The Court held that the "right to control" theory is invalid under the federal wire fraud statute, which is limited to the protection of traditional property interests only.

Whether the federal wire fraud statute's prohibition on schemes to defraud "money or property" encompasses the "right to control" theory, which criminalizes schemes that deprive a victim of potentially valuable economic information needed for informed decision-making.

The decision significantly narrowed the scope of federal fraud statutes, restricting prosecutors' ability to bring public corruption cases based on intangible harms like the deprivation of information. It invalidated a theory long used in several circuits, reinforcing limits on federal criminal law and underscoring a strict textualist approach to statutory interpretation.