On June 24, 2010, in Skilling v. United States, 561 U.S. ___ (2010), the Supreme Court vacated former Enron CEO Jeffrey Skilling’s conviction, holding that the honest services fraud statute, which makes it a crime to use the mail or wires in a scheme or artifice “to deprive another of the intangible right of honest services” passes constitutional scrutiny only when limited to bribery and kickback schemes. Skilling’s conspiracy conviction relied on the honest services fraud statute, but did not involve either bribery or kickbacks.