## Facts

- Thomas E. Maze stole a BankAmericard issued by a Louisville, Kentucky bank to Charles L. Meredith.
- Maze used the card at motels in multiple states, obtaining lodging and services while signing Meredith’s name.
- Maze knew the motel operators would mail charge slips to the Louisville bank, which would then mail billing information to Meredith as part of the ordinary credit-card clearance process.
- After Maze left, Meredith reported the card stolen.
- A federal grand jury indicted Maze on four counts of mail fraud under 18 U.S.C. § 1341 (based on the mailings of charge slips) and one count under the Dyer Act, 18 U.S.C. § 2312.

## Issues

1. Whether foreseeable mailings of credit-card charge slips through routine clearance procedures were mailings “for the purpose of executing” Maze’s fraudulent scheme under 18 U.S.C. § 1341.

## Decision

- The Supreme Court affirmed the Sixth Circuit’s reversal of Maze’s four mail fraud convictions.
- The Court held the mailings were not sufficiently related to executing the scheme because Maze had already obtained the goods and services by the time any mailing occurred.
- The Court characterized the mailings as efforts to adjust accounts among the victims (motels, bank, and cardholder), not steps that advanced the fraud.
- The Court noted the mailings tended to increase the likelihood of detection rather than further the scheme.

## Legal Principles

- Mail fraud under 18 U.S.C. § 1341 requires that the defendant use, or cause the use of, the mails “for the purpose of executing” the fraudulent scheme.
- A mailing that occurs after the scheme has reached fruition, and that primarily serves post-transaction accounting among victims, does not satisfy § 1341 even if it is foreseeable.
- The relevant inquiry is whether the mailing is part of the execution, continuation, or concealment of the scheme, not merely an expected consequence of commercial processes.

## Conclusion

Because Maze’s objective was completed when he checked out of the motels, and the later mailings only settled accounts among the victims while increasing the risk of detection, the mailings were not “for the purpose of executing” the scheme; the mail fraud convictions could not stand.


United States v. Maze, 414 U.S. 395 (1974)