Partial Dissent: A Sharp Divide
Not everyone on the panel agreed. U.S. Circuit Judge José Cabranes issued a partial dissent, warning that the majority had created a new and dangerous hurdle for prosecutors.
“This novel addition to our law ignores unambiguous and binding precedents,” Cabranes argued, stressing that confidential business information should count as property under wire fraud statutes without needing proof of “commercial value.”
Cabranes said he would have upheld Chastain’s conviction, calling the ruling a step backward in prosecuting financial misconduct in emerging markets like crypto.
Defense Celebrates, Government Silent
Chastain’s counsel, Alexandra Shapiro of Shapiro Arato Bach LLP, blasted the original conviction as a “miscarriage of justice” and praised the Second Circuit’s decision.
“We are delighted that the court set straight this important area of law,” Shapiro said in a statement.
The U.S. Attorney’s Office for the Southern District of New York, which prosecuted the case, declined to comment.
