Carpenter v. United States (1987)
- Docket
- 86-422
- Decided
- 1987-01-01
Summary
Question: (1) Can the petitioners be found guilty of securities crimes against the Wall Street Journal even though the Wall Street Journal had no interest in the securities traded? (2) Did the petitioners use mail and wire services as an essential part of their scheme to defraud the Wall Street Journal of its property? Conclusion: Yes, yes. Justice Byron R. White delivered the opinion for the unanimous Court. The Court was evenly divided as to whether or not the Wall Street Journal’s lack of interest in the securities traded cleared petitioners of the charged crimes, and because of that split, the Court deferred to the appellate court’s judgment. The Court unanimously rejected petitioners’ arguments that they did not obtain any money or property from the WSJ and therefore that the state did not prove the required elements of the mail and wire fraud statutes. The Court held that the publication schedule and the contents of the column while being intangible, were still property sufficient to warrant a conviction. In addition, the Court rejected petitioners’ arguments that Winans’ actions were simply a violation of workplace rules and could amount to defrauding. The Court determined that the dissemination of the column via mail and wire was an essential part of petitioners’ scheme, which satisfied the final element of the mail and wire fraud statute.