Second Circuit Narrows Definition of “Property” Under Wire Fraud Statute in United States v. Chastain

Overview – A split panel of the U.S. Court of Appeals for the Second Circuit, in United States v. Chastain (No. 23-7038), recently voted 2-1 to vacate convictions for wire fraud and money laundering because of improper jury instructions explaining “property” as applied to confidential business information. The divided panel held that confidential business information must possess commercial value to the company to be considered “property” under the federal criminal wire-fraud statute at 18…
By: Saul Ewing LLP