United States Second Circuit

Conviction of honest services mail fraud is affirmed where, although the jury instruction that allowed the jury to find defendant guilty of that crime without finding a bribery or kickback scheme was error, it does not merit reversal because bribery was the only theory of honest services mail fraud available to the jury based on the arguments and evidence at trial.

Appellate Information

• Decided 03/28/2013
• Published 03/28/2013

Judges

• KOELTL

Court

• United States Second Circuit

Counsel