How have the courts interpreted the word "include"?

Appellants complain that the use of the word "include" allowed the jury to determine that the statute prohibited defrauding people of things other than money or property: namely, intangible rights to honest trustee services. However, instructions cannot be judged in isolation; they must be taken as a whole when considering their propriety. United States v. Wolters, 656 F.2d 523, 526 (9th Cir.1981). Appellants fail to view the instruction in context. Although the court used the term "include," it instructed the jury only on what the law now prohibits: schemes to defraud of money or property.

We reject as meritless appellants' other arguments.