United States v. Stephens

Wayne Stephens (defendant) used his company's payroll system to submit false reimbursement requests totaling $67,395 for expenses he never incurred. No written policy explicitly banned this exact conduct, but the company required supervisor review of expense billings; Stephens complied at first, then stopped once a new, inattentive supervisor took over — he even entered his own name in the supervisor-review field. He started with small, easily-explained amounts (in case anyone noticed, he could claim clerical error) before growing bolder, until an audit caught him. Convicted of wire fraud, Stephens appealed to the Seventh Circuit, arguing he made no actual misrepresentation and that the evidence didn't show intent to defraud.