# Skilling v. United States **561 U.S. 358 (2010).** The Supreme Court sharply narrowed [[Honest Services Fraud]], holding that 18 U.S.C. § 1346 reaches only **bribery and kickback schemes** — not undisclosed self-dealing or conflicts of interest — in order to save the statute from being void for vagueness. The appellant was Jeffrey Skilling, the former Enron chief executive, convicted following the company's 2001 collapse. The Court also addressed pretrial publicity and jury impartiality, but the § 1346 holding is the one with lasting effect on public-corruption law. Skilling is the first of the two rulings that hollowed out federal corruption prosecution. It cut away the self-dealing theory; [[McDonnell v. United States]] (2016) then narrowed the definition of an "official act" underneath the bribery theory that remained. Read together they leave federal law reaching only the explicit quid pro quo — see [[Elite Impunity]] and [[Fraud Enforcement Inversion]]. > [!note] Stub — fill out > This page was created as a stub during learning-module generation on 2026-09-05. Audit and expand when convenient: the full *McNally* → § 1346 → *Skilling* sequence, Justice Scalia's concurrence urging the statute be struck entirely, the jury-prejudice holding, and the downstream charging record. ## See also - [[Honest Services Fraud]] - [[McDonnell v. United States]] - [[Bribery]] - [[Elite Impunity]] - [[Corruption]]