Loughrin v. United States, 134 S. Ct. 2384

Loughrin forged and altered checks, presenting them to Target to buy goods and then cash out, with six checks drawn on accounts at federally insured banks.
Target deposited some checks; other banks refused payment after the fraud was detected; some payments were made to Target.
Loughrin was charged under 18 U.S.C. §1344(2) for knowingly executing a scheme to obtain bank property by false pretenses; the District Court allowed §1344(2) and the jury convicted.
The Tenth Circuit affirmed, rejecting the argument that §1344(2) requires intent to defraud a bank.
The central issue is whether §1344(2) requires proof of intent to defraud a bank; the Supreme Court holds it does not.
The decision discusses statutory text, historical context, and federalism concerns regarding the reach of §1344(2).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does §1344(2) require intent to defraud a bank?	Loughrin argues §1344(2) requires intent to defraud a bank.	United States argues no such intent is required; structure of 'to obtain... by means of' suffices.	No; §1344(2) does not require intent to defraud a bank.

Neder v. United States, 527 U.S. 1 (1999) (clarified that the statute’s scope is not read to require extra elements)
McNally v. United States, 483 U.S. 350 (1987) (interpreted similar language in mail fraud statute as a single offense)
Russello v. United States, 464 U.S. 16 (1983) (presumed intent differences when Congress uses different language)
Connecticut Nat. Bank v. Germain, 503 U.S. 249 (1992) (statutory interpretation: means what it says; avoid superfluous language)
United States v. Clapps, 732 F.2d 1148 (1984) (illustrative of disjunctive readings in statute interpretation)
United States v. States, 488 F.2d 761 (1973) (historical interpretations of fee and fraud statutes)
United States v. Nkansah, 699 F.3d 743 (2d Cir. 2012) (note on banking-focused fraud reach)