In the case of Kelly v. United States (2019), Bridget Anne Kelly, a former aide to New Jersey Governor Chris Christie, was convicted for her role in the 2013 "Bridgegate" scandal involving political retribution against Fort Lee's mayor by creating traffic jams on the George Washington Bridge. The Supreme Court unanimously overturned these convictions, ruling that while Kelly's actions were deceptive and corrupt, they did not constitute federal property fraud as she did not aim to obtain money or property from her scheme. The court clarified that under federal law, schemes aimed at depriving citizens of honest services or infringing their intangible rights do not qualify as fraud unless they involve bribes or kickbacks. Therefore, despite acknowledging that Kelly’s conduct represented an abuse of power and misuse of public resources for personal gain, it fell outside the scope of specific federal criminal statutes under which she was charged.

In the dissenting opinion for Kelly v. United States, Justice Kagan, joined by Justices Ginsburg and Breyer, argued that the majority's interpretation of fraud was too narrow. They contended that while it is true not every corrupt act by a state or local official is a federal crime, when such officials deceive their constituents about real reasons behind their decisions to reallocate public resources - as in this case with lane closures on George Washington Bridge - they are committing fraud. The dissenters believed that defendants' scheme did aim to obtain money or property because they sought control over part of bridge's lanes which were physical assets monetized through tolls collected from drivers using them. Therefore, according to them, these actions fell under scope of federal law against wire fraud and should have been punishable.