Second Circuit -- United States v. Nouri

No plain error in post-Skilling fraud instruction that didn't limit honest services to bribes & kickbacks.

Same with including honest services element in instruction for securities fraud.

Court correctly instructed on finding fiduciary obligations.

No error in denial of deft's requested instruction distinguishing "incidental to" / "in connection with."

Sufficient evidence, sentence reasonable.

United States v. Nouri