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Court: US Court of Appeals for the Ninth Circuit
Docket:
21-50162
Opinion Date: April 9, 2024
Judge:
FRIEDLAND
Areas of Law:
Criminal Law, White Collar Crime
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Six defendants were convicted of mail fraud and conspiracy to commit mail fraud for their sales companies' tactics in selling printer toner. The government's case was based on the argument that a representative from the sales company would call a business, falsely imply that the sales company was the business's regular supplier of toner, and falsely state that the price of toner had increased. The representative would then state that the business could lock in the old price by purchasing more toner that day. The defendants argued that this theory of fraud was overbroad because it permitted the jury to convict even though all of the businesses received the toner they ordered at the agreed price.
The case was heard in the United States District Court for the Central District of California, where the defendants were found guilty on all counts. The defendants appealed their convictions, arguing that the government's theory of fraud was overbroad.
The United States Court of Appeals for the Ninth Circuit agreed with the defendants, holding that the government's theory of fraud was overbroad because it did not require the jury to find that the defendants deceived customers about the nature of the bargain. The court vacated the defendants' convictions and remanded the case back to the lower court.
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