In the United States v. Maze case of 1973, the Supreme Court ruled that a man who had stolen a credit card and used it to pay for motel rooms did not violate federal mail fraud statutes. The defendant, Maze, had taken his roommate's BankAmericard and used it at various motels across several states while traveling from California to Kentucky. Each time he checked out of a motel, an invoice was mailed back to the bank in California which then sent bills to the owner of the card in Kentucky. The court held that although there was deceit involved in this act, there wasn't any use of mails as part of executing this scheme since mailing occurred after each fraudulent transaction was completed successfully without detection or failure. Therefore, these actions didn’t fall under mail fraud according to existing laws at that time.

In the dissenting opinion for United States v. Maze, Justice Blackmun argued that the majority's interpretation of the federal mail fraud statute was too narrow. He believed that Maze's fraudulent use of a stolen credit card and subsequent mailing of invoices by merchants to the issuing bank constituted a scheme to defraud through use of mails, even if those mailings occurred after goods were obtained. In his view, these actions fell within both letter and spirit of law as it aimed at punishing schemes devised with intent to defraud or obtain money/property via false pretenses using postal system in execution thereof. The fact that banks suffered loss only after being billed by merchants did not negate this reality; rather it emphasized how integral mails were in realizing defendant’s fraudulent plan. Thus, he disagreed with majority’s assertion that because mailed items contained no misrepresentations themselves nor contributed directly towards victim’s decision-making process they could not be considered part of fraud scheme under said statute.