United States v. Maze

Background

In 1971 a man living in Kentucky took his roommate’s BankAmericard and used it at motels in California, Florida, and Louisiana. Merchants sent invoices by mail to the Louisville bank that issued the card, and the cardholder reported the card stolen. After the man's return, he was indicted on four mail‑fraud counts and one car‑theft (Dyer Act) count, tried and convicted by a jury, and the court of appeals reversed the mail‑fraud convictions but affirmed the car‑theft conviction. Because courts of appeals were divided about when credit‑card misuse violated the mail‑fraud law, the Government asked the Supreme Court to resolve the question.

Reasoning

The Court assumed the defendant’s actions led to the mailings but asked whether those mailings were made “for the purpose” of executing the fraud. It reviewed earlier cases (Kann, Pereira, and Sampson) and the Government’s argument that mailing delays help fraudsters continue undetected. The Court concluded that the motel invoices were routine account adjustments sent to settle accounts and not essential steps to carry out the fraud; in fact, those mailings likely made detection more likely. The Court therefore held the mail‑fraud statute did not apply to these mailings and affirmed the court of appeals on that point.

Real world impact

The ruling narrows when ordinary business mailings can form the basis of federal mail‑fraud charges in credit‑card cases. Federal prosecutors will have a smaller set of mailings that qualify, potentially shifting many interstate card fraud prosecutions to state courts. The opinion also noted that Congress recently enacted a separate statute targeting large‑value credit‑card fraud but did not base its decision on that law.

Dissents or concurrances

Several Justices dissented, arguing the mailings and their delay were central to the fraud and that the decision would weaken federal ability to combat widespread credit‑card fraud.