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The essential idea is how honest-services fraud is applied. The Supreme Court clarified that when someone is charged with honest-services fraud, the government must prove a bribery or kickback scheme—essentially a quid pro quo in exchange for official actions. In Skilling’s case, the Court held that simply engaging in undisclosed conflicts of interest or self-dealing isn’t enough unless there is evidence of a paid exchange for specific actions. He did not accept bribes or kickbacks as an Enron officer, so the basis for the honest-services conviction didn’t hold under that narrowed standard. This is why the ruling focused on the absence of bribery or kickbacks. Note that other charges, like securities or wire fraud, could still be pursued if the facts support them, but the honest-services theory requires that payment-for-favor element to sustain a conviction.