Skilling v. United States

Summary

The Court held that extensive pretrial publicity and community hostility did not deprive Skilling of a fair trial because neither presumptive nor actual juror prejudice was established. It also construed the honest-services statute to reach only bribery and kickback schemes, rendering the statute constitutional as construed but making Skilling's charged conduct outside its scope. The conspiracy conviction was therefore vacated for further harmless-error analysis, while the fair-trial ruling was affirmed. Justice Sotomayor, joined by Justices Stevens and Breyer, would have granted relief on the fair-trial claim; Justice Scalia would have invalidated the honest-services statute as vague; and Justice Alito concurred in the judgment while advocating an actual-bias approach.