Jeffrey Skilling, former CEO of Enron Corporation, was prosecuted for, among other things, engaging in a scheme to deceive investors about Enron's true financial performance by manipulating its publicly reported financial results and making false and misleading statements. He was prosecuted for committing "honest services" wire fraud, by depriving Enron and its shareholders of the intangible right of his honest services.
The Supreme Court decided, in order to avoid declaring the statute unconstitutionally vague, to construe the honest services provision to apply only to bribes and kickbacks, which Skilling did not take. It reversed his conviction on that count and sent the case back to the lower court to determine if any of the other convictions for money or property wire fraud or securities fraud would be affected by this narrow interpretation of the statute.