State v. Schneider
In State v. Schneider, 148 Ariz. 441, 715 P.2d 297 (App. 1985), the alleged misrepresentations had been made directly to each victim, who thereafter invested in what was referred to as a "Ponzi" scheme. Schneider, 148 Ariz. at 443, 715 P.2d at 299.
In refusing a requested instruction on reliance, the trial court found the instruction on material misrepresentation covered the term. Id. at 444, 715 P.2d at 300.
Affirming the conviction on appeal, this court acknowledged that reliance is an element of the offense, but found essentially the same instruction that was given here made that clear to the jury. Id. at 444-45, 715 P.2d at 300-01.