By: WISCONSIN LAW JOURNAL STAFF//March 26, 2015//
U.S. Court of Appeals For the Seventh Circuit
Criminal
Bribery – Sufficiency of the evidence
Where the defendants believed an undercover officer was a county official willing to accept a bribe, the evidence was sufficient to convict them of conspiracy to commit bribery.
“There is also abundant evidence in the record that, regardless of which entity or entities employed the fictional corrupt official, the conspirators reasonably believed Castro’s claims that the official could act on behalf of Los Angeles County. The allure of the deal and the reason for paying the agreed bribe were precisely that this corrupt official could guarantee approval for the sizeable contract by the county’s Board of Supervisors. And by definition, a person qualifies ‘as an agent of an entity’ when he is ‘authorized to act on behalf of that entity.’ United States v. Keen, 676 F.3d 981, 990 (11th Cir. 2012). The jury heard sufficient evidence to support its finding that the $10,000 element was satisfied beyond a reasonable doubt.”
Affirmed.
14-1278 and 14-1100 U.S. v. Buenrostro
Appeals from the United States District Court for the Northern District of Illinois, Tharp, J., Hamilton, J.