Archive | corruption

In United States v. Dean Skelos and Adam Skelos, 2d Cir. Nos. 18-3421 & 18-3442 (Feb. 23, 2021), a panel of the Court (Walker, Sack, and Carney) affirms the Skeloses’ convictions, following a 2018 retrial, for various public-corruption and bribery related offenses (Dean Skelos was the Majority Leader of the New York State Senate and Adam Skelos is his adult son). Their earlier convictions, following a 2015 trial, had been vacated in light of the Supreme Court’s decision in “McDonnell v. United States, 136 S. Ct. 2355 (2016), which narrowed the definition of the ‘official act’ that a public official must exchange for benefits in order to be convicted of Hobbs Act extortion or honest services fraud, where those crimes have been defined by reference to the term ‘official act’ in the federal bribery statute, 18 U.S.C. § 201. Because the McDonnell definition conflicted with the broader …