United States First Circuit

Defendant's conviction for bribery, extortion, and conspiracy charges stemming from his involvement in a scheme to purchase the votes of three corrupt town councilmen on two zoning matters is affirmed where: 1) recorded statements were admissible as nonhearsay under Rule 801(d)(2)(E) because they were all made during the course of, and in furtherance of, the conspiracy in which defendant was an active member; 2) there was no consitutional error in admitting the recorded statements; and 3) increases to defendant's base offense level were warranted.

Appellate Information

• Decided 10/05/2012
• Published 10/05/2012

Judges

• Lipez

Court

• United States First Circuit

Counsel