Cleveland v. United States

Carl Cleveland (defendant) helped conceal the true ownership of a video-poker business by naming his business partner's adult children, rather than himself and the actual owner, on state license applications mailed to Louisiana, which required disclosure of true ownership to ensure licensees' good character. He was convicted of mail fraud for these misrepresentations, on the theory that the misrepresentations deprived the state of "property" — the licenses themselves. The court of appeals affirmed, and the Supreme Court granted certiorari.