The Supreme Court has recognized that the mail and wire fraud statutes sweep
more broadly than the common law definition of fraud and false pretenses.
Durland v. United States, 161 U.S. 306, 313-14 (1896).5 However, the Court
also rejected the notion that every “scheme or artifice that in its necessary
consequence is one which is calculated to injure another [or] to deprive him
of his property wrongfully.”