Does a jury have to agree that self-dealing and undisclosed conflicts of interest constitute honest services fraud?
MultiRegion, United States of America
The following excerpt is from United States v. Hernandez, 20-50012 (9th Cir. 2021):
1. Hernandez claims the district court erred in failing to instruct the jury that self-dealing and undisclosed conflicts of interest do not constitute honest-services fraud under 18 U.S.C. 1346. See Skilling v. United States, 561 U.S. 358, 412 (2010). We review for plain error and conclude the instructions were not erroneous. United States v. Campbell, 42 F.3d 1199, 1204 (9th Cir. 1994).
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