United States Fourth Circuit

In a prosecution of a former U.S. congressman for offenses arising from his involvement in multiple bribery and fraud schemes, all convictions but one are affirmed, where: 1) the trial court did not improperly instruct the jury on the definition of an "official act" under the federal bribery statutes; 2) an instruction with respect to the "quid pro quo" element of the bribery-related offenses was not erroneous; 3) an erroneous jury instruction on the self-dealing theory of honest services wire fraud was harmless; and 4) venue was improper on one of the wire fraud charges.

Appellate Information

• Decided 03/26/2012
• Published 03/26/2012

Judges

• King

Court

• United States Fourth Circuit

Counsel

• For Appellant:
  
• Lawrence Robbins, Mark D. Lytle