in response to the Supreme Court's 1987 decision in United States v. McNally, which held that 78 U.S.C. § 1341 did not cover "honest services" fraud. Gaioni, supra note 162, at 243 n.192. 164 See, e.g., Perrin, 444 U.S. at 50 (finding that section 1952 reflects congressional intent "to alter the federal-