The Court decided to limit the application of the statute only to defendants who hold a fiduciary duty and they participate in bribery and kickback schemes.

The Court supported its decision not to rule the statute void for vagueness on its obligation to construe and not condemn Congress' laws.

In light of the court's findings, a similar case, Weyhrauch v. United States, involving former Alaska representative Bruce Weyhrauch,[1] was returned to the United States Court of Appeals for the Ninth Circuit, where federal charges were eventually dropped.

[2][3] The Supreme Court heard the Skilling case along with the similar Black v. United States (2010).

The later case of Ciminelli v. United States (2023) further narrowed the application of the statute, quoting Skilling.