What is the test for overturning a conviction for mail and wire fraud?

MultiRegion, United States of America

The following excerpt is from U.S. v. Sabatini, 874 F.2d 817 (9th Cir. 1989):

Sabatini relies on United States v. Mastelotto, 717 F.2d 1238 (9th Cir.1983), which reversed the defendants' conviction for mail and wire fraud because the district court failed to require the jury to agree on the same single scheme to defraud.

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