The ancient notion that private fraud lies beyond the domain of public law did not long survive the statements of it that have been quoted.' Our legislation, expressing always the changing moral standards of the people, has directed the sanctions of the criminal law, step by step, ever against new forms of overreaching and imposition. Numerous illustrations might be cited to show the growing repugnance of the public mind toward frauds and cheats, and the tendency to recognize them as offenses invoking the restraint of public action as well as the redress of private injuries.
Clarence D. Laylin,
The Ohio "Blue Sky" Cases,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol15/iss5/2