Justia White Collar Crime Opinion Summaries

A longtime Speaker of the Illinois House of Representatives was prosecuted in federal court for engaging in extensive bribery schemes. The first involved a major utility company, Commonwealth Edison (ComEd), which, facing financial difficulties, funneled more than $3 million to the defendant’s political associates through intermediaries and sham contracts in exchange for the defendant’s legislative support of ComEd’s agenda over several years. The government presented evidence that these payments resulted in concrete legislative actions by the defendant that benefitted ComEd, including support for specific bills and regulatory changes. The second scheme involved the defendant’s agreement to recommend a Chicago alderman for a state board appointment in exchange for business referrals and benefits to the defendant’s family.Following a lengthy trial in the United States District Court for the Northern District of Illinois, the jury convicted the defendant on several counts, including conspiracy, federal-program bribery, honest-services wire fraud, and Travel Act violations. The jury acquitted him on some counts and was deadlocked on others. The district court denied the defendant’s motions for acquittal and for a new trial, then imposed a sentence of imprisonment and a substantial fine.On appeal to the United States Court of Appeals for the Seventh Circuit, the defendant challenged the sufficiency of the evidence and the adequacy of the jury instructions. The Court of Appeals held that sufficient evidence supported each conviction and found no prejudicial error in the jury instructions, including those related to the definition of “official act,” “corruptly,” and the intent elements of bribery. The court also concluded that any potential instructional error regarding state law bribery under the Travel Act was harmless beyond a reasonable doubt. The convictions and sentence were affirmed. View "USA v. Madigan" on Justia Law