United States Ninth Circuit

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US v. Rodrigues, 11-15530

Convictions for theft of honest services, money laundering, and health care fraud are affirmed, even though the jury was not instructed on the kickback element of the crime of theft of honest services, where such omission was harmless error because: 1) the defendant was on notice that he was facing charges that included allegations of conduct that qualified as kickbacks; and 2) the government’s convincing evidence overwhelmingly proved its charges relating to the kickbacks.

Appellate Information

  • Decided 03/27/2012
  • Published 03/27/2012


  • Trott


  • United States Ninth Circuit


  • For Appellant:
  • Eric A. Seitz, Lawrence L. Tong