arsenal. The statute makes criminal a broad range of schemes to defraud but is not limitless, as seen prominently in the landmark 2020 U. S. Supreme Court Kelly v. U. S. decision, which held that violations of the wire fraud statute require not only deception, but also an intent to obtain property through the scheme. [1]Last month, the U. S. District Court for the District of Columbia weighed in on another limiting factor: what it means to obtain money or property, as required by Kelly. . . .
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