Carpenter v. United States
United States Supreme Court
484 U.S. 19 (1987)
Wall Street Journal (the Journal) columnist R. Foster Winans (defendant), despite knowing his prepublication column content was confidential, secretly agreed with stockbrokers Kenneth Felis and Peter Brant (defendants) to reveal upcoming column contents and release dates so they could trade profitably beforehand, generating roughly $690,000 in net trading profits over four months before the scheme was discovered. Winans and his roommate David Carpenter (defendant) eventually reported the scheme to the SEC; Winans and Felis were convicted of mail and wire fraud and Carpenter of aiding and abetting, and Winans and Felis appealed, arguing the scheme wasn't a fraud within the statute's scope and that the Journal lost no property as the statute required.
Whether the mail-fraud statute is limited to protecting tangible property rights.