News & Events

Bill Zapf and Jon Jeffress Co-Author an Article in The Champion® on Honest-Services Fraud in the Private Sector After Skilling v. United States

The U.S. Supreme Court saved 18 U.S.C. § 1346 and the Honest-Services Doctrine from the void-for-vagueness dust heap in Skilling v. United States.

In a recent article found on page 26 of The Champion® September/October 2019 Issue, counsel Bill Zapf and partner Jon Jeffress explore certain “limiting principles” courts have followed that may be avenues for challenging an honest-services prosecution. In addition, they include a brief survey detailing how circuit court pattern jury instructions cover honest-services fraud.

The article can be found here – copyright owned by the NACDL.