 The mail fraud statute , 18 U.S.C. § 1341 , " [ t ] he oldest statute used to address public corruption , " was enacted in 1872 and first used against public corruption in the 1940s . While several early cases employed the " intangible right to honest government , " United States v. States ( 8th Cir . 1973 ) was the first case to rely on honest services fraud as the sole basis for a conviction . 
