Tim O'Toole comments on the Supreme Court's Skilling decision, which limited the scope of the honest services fraud statute. The decision will have profound implications for criminal cases involving business executives and public officials charged with fraud, since it applies to all pending cases and to all cases not yet final on direct appeal, says O'Toole. Prior to the Skilling decision, the statute "could be made to fit any sort of conduct that looked bad," O'Toole says. "Those days are gone."