What is the current state of the law on fraud based on a relationship between an employer and employee?

MultiRegion, United States of America

The following excerpt is from United States v. Napout, 963 F.3d 163 (2nd Cir. 2020):

Federal courts began to recognize this theory of fraud based on private employer-employee relationships in the 1940s. See Skilling v. United States , 561 U.S. 358, 400, 130 S.Ct. 2896, 177 L.Ed.2d 619 (2010). "In perhaps the earliest application of the theory," id. at 401, 130 S.Ct. 2896, a district court in Massachusetts explained:

[963 F.3d 180]

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