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Take theft of honest services.
Ultimately, a jury acquitted Mr. Bruno of six counts of honest services fraud.
The decision threw into limbo dozens of "honest services" cases around the country.
Earlier this month, Mr. Bruno was convicted on two felony counts involving "theft of honest services".
Those counts include mail fraud, wire fraud and theft of honest services.
Prosecutors had argued that the bankers robbed Enron shareholders of "honest services".
"My conduct had the effect of depriving others of honest services," he said.
Instead, he was convicted of five counts of honest services fraud, one of bribery and one of obstruction.
BEHIND THE NEWS The law made it a crime to deprive another of the intangible right of honest services.
The court ruled that theft of honest services was relevant only in cases involving bribes and kickbacks.
If they failed to do so, they deprived the company of "honest services" and committed a crime.
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CEO of Professional Science Editing for Scientists @ prosciediting.com