On June 23, 2014, the U.S. Supreme Court clarified – and arguably expanded – the reach of the federal bank fraud statute. In Loughrin v. U.S., petitioner Kevin Loughrin challenged the lower court’s interpretation of the federal bank fraud statute as not requiring that the government prove that the defendant specifically intended to defraud a bank. The Supreme Court disagreed.

This case originated in the petitioner’s check fraud scheme orchestrated at a Target Store. The petitioner, while pretending to be a Mormon missionary, went door-to-door in a neighborhood in Salt Lake City, where he rifled through residential mailboxes and stole any checks he found. (Why nobody thought it suspicious that a purported Mormon missionary was (1) working a mission project without a partner, and (2) doing so in what is arguably the U.S. city least in need of conversion to the LDS faith, will be left for another day.) The petitioner would then make the checks out to the retailer Target for amounts of up to $250. His modus operandi was to go into a local Target, posing as the account holder, and present the altered check to a cashier to purchase merchandise. After the cashier accepted the check, the petitioner would leave the store and walk back inside to return the goods for cash. In each case, the checks presented to Target were drawn on an account at a federally insured bank.

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