"Things gained through unjust fraud are never secure." Sophocles, the ancient Greek playwright, understood this nearly 1,000 years ago when he wrote "Oedipus at Colonus," but the 9th U.S. Circuit Court of Appeals has vacilated. When considering what elements are necessary to prove mail or wire fraud, the court has changed course on the elements at least four times in the last 25 years. Specifically, it has added then removed, adde...
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