Honest services fraud and Citizens United: any hints?

Legal analysts are wringing just about everything they can wring out of Citizens United.  (And there’s a lot.)  So what might Citizens United mean for the honest services fraud cases the Supreme Court is weighing?  Two big cases have already been argued (Black and Weyhrauch) and oral argument is coming up in another (Skilling).  There’s no reference to honest services fraud in the opinion, so we are left reading between the lines.  The Court was unwilling to equate “influence over or access to elected officials” with the governmental interest in preventing corruption or the appearance of corruption.  The Court notes that the “appearance of influence or access” won’t cause a loss of “faith in our democracy.”

In one passage, the Court explains that “[p]rolix laws chill speech for the same reason that vague laws chill speech:  People ‘of common intelligence must necessarily guess at [the law’s] meaning and differ as to its application.’  Connally v. General Constr. Co., 269 U. S. 385, 391 (1926).”  I didn’t see Connally cited in Weyhrauch’s brief, but it cites another case, United States v. Reese, 92 U.S. 214 (1875) (“Every man should be able to know with certainty when he is committing a crime.”).

After Citizens United, does the Court seem more or less likely to limit the reach of honest services fraud?

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