In the case of Carl W. Cleveland v. United States, 2000, the U.S. Supreme Court ruled that federal mail fraud statutes could not be applied to a state-licensed video poker operator who had lied about his income on financial statements submitted to banks for loans and credit extensions. The court held that these false statements did not constitute an attempt to defraud a property right as defined by federal law because they were made in relation to obtaining bank loans rather than directly affecting any government licensing process or regulatory authority over gaming operations within the state of Louisiana where he operated his business. This decision clarified how far-reaching federal fraud laws can extend into areas traditionally regulated by states, such as gambling operations.

In the dissenting opinion for Carl W. Cleveland v. United States, Justice Ginsburg argued that the majority's interpretation of "proceeds" in the federal money laundering statute was overly broad and inconsistent with Congress' intent when it enacted the law. She contended that "proceeds" should be interpreted to mean profits rather than gross receipts because this would better align with common understanding and usage of the term. Furthermore, she pointed out that interpreting proceeds as gross receipts could potentially criminalize a wide range of ordinary business transactions which are not typically associated with money laundering activities, thereby expanding federal jurisdiction into areas traditionally regulated by state law enforcement agencies.