Ciminelli v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Ciminelli v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Ciminelli v. United States.
In Ciminelli v. United States, the Supreme Court addressed the validity of the Second Circuit's right-to-control theory under the federal wire fraud statute. The Court found that the right to valuable economic information is not a traditional property interest and cannot form the basis for a conviction under federal fraud statutes. The decision reversed and remanded the Second Circuit's affirmation of Ciminelli's wire fraud convictions.
Holding
The single most important “bottom line” of what the Court decided in Ciminelli v. United States.
The Court held that the right-to-control theory cannot form the basis for a conviction under the federal fraud statutes.
Constitutional Concepts
These are the Constitution-related themes that appear in Ciminelli v. United States. Click a concept to see other cases that involve the same idea.
-
Why Judicial Review is relevant to Ciminelli v. United States
The Court exercised its power of judicial review to determine the validity of the Second Circuit's right-to-control theory under the federal fraud statutes.
Syllabus excerpt (verbatim)The right-to-control theory cannot be squared with the text of the federal fraud statutes, which are 'limited in scope to the protection of property rights.'
-
Why State–Federal Power is relevant to Ciminelli v. United States
The decision implicates the allocation of authority between state and federal governments by limiting the scope of federal jurisdiction over fraud cases traditionally left to state law.
Syllabus excerpt (verbatim)Finally, by treating mere information as the protected interest, the right-to-control theory vastly expands federal jurisdiction to an almost limitless variety of deceptive actions traditionally left to state law.
Key Quotes
Short excerpts from the syllabus in Ciminelli v. United States that support the summary and concepts above.
The right-to-control theory cannot be squared with the text of the federal fraud statutes.
The Government now concedes that the theory as articulated below is erroneous.
The Court declines the Government's request, which would require the Court to assume not only the function of a court of first view, but also of a jury.