scope of the common law concepts of fraud to which McNally sought to restrict the mail fraud statute. See United States v. Sorich, 523 F.3d 702, 712–13 (7th Cir. 2008) (scheme creating fraudulent hiring bureaucracy for city employees led to “salaries fraudulently obtained” and “job opportunities fraudulently denied,” both of which “represent[ed] property for purposes of mail fraud”); United States v. Granberry, 908 F.2d 278, 280 (8th Cir. 1990) (scheme to obtain “wages paid” by falsifying application “is within the narrowest reading of the [mail fraud] statute”); United States v. Doherty, 867 F.2d 47, 54–57 (1st Cir. 1989) (Breyer, J.) (indictment alleging scheme to rig police promotion exam and make fraudulent appointments deemed “sufficient to charge a valid conspiracy to defraud the Commonwealth of ‘money or property,’ namely, a scheme ‘for obtaining’ the money used to pay the salaries of those improperly promoted ‘by means of false or fraudulent pretenses’”) (quoting 18 U.S.C. § 1341); United States v. O’Brien, 994 F. Supp. 2d 167, 182–83 (D. Mass. 2014) (scheme to hire and promote unqualified probation department employees); United States v. Ferrara, 701 F. Supp. 39, 41–42 (E.D.N.Y. 1988) (scheme to obtain hospital salaries by falsifying medical training), aff’d, 868 F.2d 1268 (2d Cir. 1988); United States v. Thomas, 686 F. Supp. 1078, 1083–85 (M.D. Pa. 1988) (scheme to rig police entrance exam), aff’d, 866 F.2d 1414 (3d Cir. 1988) (table); cf. United States v. Cooper, 677 F. Supp. 778, 781–82 (D. Del. 1988) (wire fraud scheme to obtain pay for person not performing work). This salary theory of post-McNally mail or wire fraud has potential application to some election fraud schemes, since most elected offices in the United States carry with them a salary and various emoluments that have monetary value. For example, schemes to obtain salaried elected positions through procuring and tabulating invalid ballots, or by concealing from a supervising authority the receipt of illegal campaign funds during an election, result in the payment of a salary to an official who would not have been elected absent the fraud. In addition, election fraud schemes can present related issues concerning the quality and value of the public officer hired thereby. 68