To combat telemarketing fraud, Congress amended the mail fraud
statute
to broaden its application to include private or commercial interstate
carriers
in addition to the United States Postal Service. See Senior Citizens
Against Marketing Scams Act of 1994, Pub.L. No. 103-322, Title XXV, §
25006,
and Title XXXIII, § 330016(1)(H), 108 Stat. 2087, 2147 (enacted as part
of
the Violent Crime Control and Law Enforcement Act of 1994); see also
Cong.
Rec. S2654-61 (March 10, 1993) (statement of Sen. Hatch) and S10017-19 (July
30,
1993) (statement of Sen. Hatch).
QUERY: What is an interstate carrier? See generally Peter
J.
Henning, Maybe it Should Just be Called Federal Fraud: The Changing
Nature of
the Mail Fraud Statute, 36 B.C.L. Rev. 435, 473-77 (1995) ("The large
delivery service companies, such as Federal Express and United Parcel
Service,
are clearly interstate carriers, but small entities, such as local messenger
services, are not as easily categorized.").