US v. Yates, No. 18-30183 (10-8-21)(Berzonw/Miller; Bress dissenting). A majority of the 9th held that a conspiracy for bank fraud and false entry had to be vacated because the theory of a duty to accurate information was too an ethereal theory for a conviction. The other conviction had to be vacated for insufficient evidence. 

Dissenting, Bress would find the convictions supported prior precept.

Congrats to Elizabeth Daly and Steve Sady, Ore FPD (Portland). 

The decision is here:

https://cdn.ca9.uscourts.gov/datastore/opinions/2021/10/08/18-30183.pdf