United States Second Circuit

Conviction and sentencing of defendant, a former UN employee, of corruption-related charges are upheld because: 1) defendant's immunity was waived by the UN and by his own failure to assert it during trial; 2) the UN Participation Act is both a "federal program" and a “benefit” within the meaning of 18 U.S.C. section 666; 3) Section 1346 encompasses honest services fraud committed by a foreign worker at the UN; and 4) the court correctly ordered defendant to pay restitution in the form of remitting a portion of his salary.

Appellate Information

• Decided 10/26/2011
• Published 10/26/2011

Judges

• POOLER

Court

• United States Second Circuit

Counsel