Granberry, 908 F.2d at 280; United States v. Thomas, 686 F. Supp. 1078, 1085 (M.D. Pa. 1988); Webb, 689 F. Supp. at 707 (characterizing “[a] net loss in the salary expended” as “superfluous” to a mail fraud charge). Moreover, the net expense rationale ignores the Supreme Court’s observation in McNally, quoted above, that fraud causing a lower-quality service to be provided can give rise to a viable mail fraud claim. See Schermerhorn, 713 F. Supp. at 92 (explaining that the defendant’s emphasis on overall cost “is at the expense of the remainder of that disjunctive clause – ‘or secured better insurance’”) (quoting McNally, 483 U.S. at 360)); Granberry, 908 F.2d at 280 (“What the school district wanted was a competent school-bus driver who was truthful and had not been convicted of a felony, and this is not what it got.”). Neither the statutory language nor common law concepts of fraud require courts to “abide [or] judicially sanction the conclusion that corrupt and non-corrupt elected officials are of equal value.” Schermerhorn, 713 F. Supp. at 92. The Fifth Circuit’s holding in Ratcliff also rested on its observation that the defendant’s fraudulent misrepresentations were aimed directly at a local ethics board, rather than the locality paying the official’s salary. Ratcliff, 488 F.3d at 644–45. However, just three years later, in United States v. McMillan, the circuit disavowed that line of reasoning, acknowledging that “[n]othing in the mail and wire fraud statutes requires that the party deprived of money or property be the same party who is actually deceived.” 600 F.3d 434, 449 (5th Cir. 2010) (internal quotation marks omitted). The McMillan court instead read Ratcliff’s holding to rely principally upon the first basis explained above, i.e., the fact that the elected official’s “salary and benefits . . . would have been paid regardless of the defendant’s misrepresentations.” Id. at 448. Finally, in Turner, the Sixth Circuit based its holding in part on its view that the locality paying the official’s salary lacked “control over the appropriation of the salary beyond ensuring payment to the duly elected official.” Turner, 465 F.3d at 682. But there is no support in the statutory language for such a limitation. See 18 U.S.C. §§ 1341, 1343 (making unlawful “any scheme or artifice to defraud, or for 71