Jeffrey Skilling's long appeals finally ended last month, when the courts shaved a decade off the prison sentence he received for his role in the Enron Corp. debacle. But the landmark U.S. Supreme Court ruling that bears his name has done little to convince appellate courts to reverse jury verdicts involving the honest-services fraud statute, under which Skilling had been convicted.

The Supreme Court's 2010 opinion in Skilling v. U.S. at first seemed a big win for individuals convicted under the statute, many of them politicians or others caught up in corruption scandals. The high court restricted honest-services fraud to cases involving bribery or kickbacks, rather than conflicts of interest.