Ciminelli v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Ciminelli v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Ciminelli v. United States.
In Ciminelli v. United States, the Supreme Court reviewed the conviction of Louis Ciminelli for wire fraud under the right-to-control theory. The Court found that the right to valuable economic information is not a traditional property interest under the federal fraud statutes. Consequently, the Second Circuit's reliance on this theory was not valid for a wire fraud conviction.
Holding
The single most important “bottom line” of what the Court decided in Ciminelli v. United States.
The Court held that the right-to-control theory cannot form the basis for a conviction under the federal fraud statutes.
Constitutional Concepts
These are the Constitution-related themes that appear in Ciminelli v. United States. Click a concept to see other cases that involve the same idea.
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Why Judicial Review is relevant to Ciminelli v. United States
The Court's decision involves reviewing and invalidating the Second Circuit's interpretation of the wire fraud statute.
Syllabus excerpt (verbatim)The right-to-control theory cannot be squared with the text of the federal fraud statutes, which are 'limited in scope to the protection of property rights.'
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Why Procedural Due Process is relevant to Ciminelli v. United States
The Court's decision impacts the procedural fairness of the trial by rejecting the theory used to convict Ciminelli.
Syllabus excerpt (verbatim)The Government now concedes that the theory as articulated below is erroneous.
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Why Void for Vagueness is relevant to Ciminelli v. United States
The Court's rejection of the right-to-control theory suggests concerns about the vagueness of using such a theory to define criminal conduct.
Syllabus excerpt (verbatim)By treating mere information as the protected interest, the right-to-control theory vastly expands federal jurisdiction to an almost limitless variety of deceptive actions traditionally left to state law.
Key Quotes
Short excerpts from the syllabus in Ciminelli v. United States that support the summary and concepts above.
The right-to-control theory cannot be squared with the text of the federal fraud statutes.
The so-called right to control is not an interest that had 'long been recognized as property.'
The Government now concedes that the theory as articulated below is erroneous.
