The Supreme Court last week, in the case of Skilling v. United States and two companion cases, severely curtailed the reach of the federal mail and wire fraud statutes by confining the “intangible right of honest services” to only those schemes that involve bribes or kickbacks. In so doing, the Court rejected the government’s argument that honest-services fraud should apply more broadly to undisclosed self-dealing and conflicts of interests. Justice Ginsburg wrote for the Court. Three other Justices (Justices Scalia, Thomas, and Kennedy) concurred in the judgment but would have gone even further and struck down the honest-services fraud provision in its entirety, finding it unconstitutionally vague and therefore in violation of the Due Process Clause of the Fifth Amendment.1