Louis Ciminelli, Petitioner v. United States, et al.

The Court rejected the Second Circuit's “right to control” theory and reversed and remanded Ciminelli's case. It said federal fraud laws do not treat a person's right to complete and accurate economic information as traditional property.

Federal prosecutors cannot rely solely on the right-to-control theory in fraud cases. Defendants whose cases rested on that theory may challenge convictions or charges based on it.

Lower courts must apply the decision and cannot use the right-to-control theory as a basis for federal fraud liability. Ciminelli's case returns for further proceedings consistent with the Court's decision.

The Court rejected the right-to-control theory of federal fraud and reversed and remanded the case. Useful economic information alone is not traditional property.

Federal prosecutors and defendants in cases relying on the right-to-control theory are affected. Courts cannot treat lost decision-making information alone as property fraud.

The case returns for further proceedings under the Court's rule. Lower courts must assess fraud claims without using the rejected right-to-control theory.