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Federal Criminal Defense Blog Federal Criminal Defense and Civil Litigation in Georgia and Beyond

9th Circuit Reverses CA City Treasurer’s “Honest Services Fraud” Convictions

Posted in Acquittal, Fraud

On Monday, the U.S. 9th Circuit Court of Appeals ordered Albert Robles, former Treasurer for South Gate, California, acquitted on three charges for “honest services fraud,” 18 U.S.C. 1346, which Mr. Robles had been convicted on in 2006. The Court also reversed the honest services conviction of Robles’ business associate, George Garrido. The reversals were based upon the U.S. Supreme Court’s decision in U.S. v. Skilling, 130 S. Ct. 2896 (2010), in which the Supreme Court held that 18 U.S.C. 1346, which prohibits fraudulent deprivations of “the intangible right of honest services,” is limited to bribery and kickback schemes.

Robles was prosecuted for taking nearly $2 million in bribes from contractors.

The Court held that the jury was wrongly instructed at trial that it could convict Robles by finding that he failed to disclose financial conflicts of interest. It left Robles’ conviction for bribery intact. The story was reported at Silicon Valley MercuryNews.com.


“Justice in the life and conduct of the State is possible only as first it resides in the hearts and souls of the citizens.” — Plato

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