United States v. Zar, — F.3d —-, 2015 WL 3853602 (10th Cir. June 23, 2015)

In this complex wire fraud and money laundering case, the Tenth Circuit affirmed the convictions of two individuals who had created or participated in a fraudulent real estate scheme. On appeal, the defendants argued that the district court incorrectly instructed the jury on the elements of wire fraud, because the court removed the phrase “defraud or” from its instructions. The Tenth Circuit disagreed and held the instruction did not omit an essential element of the crime of wire fraud, because the remaining language, which required the jury to find the defendants “devised, intended to devise, or joined a scheme to obtain money or property,” described a specific type of fraudulent scheme within the statute.