This is a list of notable United States unincorporated territory officials convicted of federal public corruption offenses for conduct while in office. The list is organized by office. Non-notable officials, such as sewer inspectors and zoning commissioners, are not included on this list, although they are routinely prosecuted for the same offenses. Acquitted officials are not listed (if an official was acquitted on some counts, and convicted on others, the counts of conviction are listed). Officials convicted of territorial crimes are not listed.
The criminal statute(s) under which the conviction(s) were obtained are noted. If a defendant is convicted of a conspiracy to commit a corruption offense, the substantive offense is listed. Convictions of non-corruption offenses, such as making false statements, perjury, obstruction of justice, electoral fraud, and campaign finance regulations, even if related, are not noted. Nor are derivative convictions, such as tax evasion or money laundering. Officials convicted only of non-corruption offenses are not included on this list, even if indicted on corruption offenses as well. Certain details, including post-conviction relief, if applicable, are included in footnotes.
The Hobbs Act (enacted 1934), [1] the mail and wire fraud statutes (enacted 1872), including the honest services fraud provision, [2] the Travel Act (enacted 1961), [3] the Racketeer Influenced and Corrupt Organizations Act (RICO) (enacted 1970), [4] and the federal program bribery statute, 18 U.S.C. § 666 (enacted 1984), [5] have been used to prosecute of such officials. These statutes are also applicable to corrupt federal, state, and local officials. [6] The Ninth Circuit has held that the program bribery statute does not apply to Guam.
| Official | Office | Crime(s) | Notes |
|---|---|---|---|
| Katherine Bordallo Aguon | Director of the Department of Education of Guam | Hobbs Act | [7] |
| Ricardo Bordallo | Governor of Guam | Hobbs Act and program bribery | [8] |
| Joseph Soriano | Director of the Department of Parks and Recreation of Guam | Hobbs Act and mail fraud | [9] |
| Official | Office | Crime(s) | Notes |
|---|---|---|---|
| James A. Santos | Commerce Secretary of the Northern Marianas Islands | Wire fraud, program bribery, and conspiracy to defraud the United States | [10] |
| Timothy Villagomez | Lieutenant Governor of the Northern Mariana Islands | Wire fraud, program bribery, and conspiracy to defraud the United States | [10] |
| Official | Office | Crime(s) | Notes |
|---|---|---|---|
| Liborio Ruben Caro-Muñiz | Mayor of Rincón, Puerto Rico | Program bribery | [11] |
| Juan Manuel Cruzado Laureano | Mayor of Vega Alta, Puerto Rico | Hobbs Act and program bribery | [12] |
| Jorge de Castro Font | Puerto Rico senator | Hobbs Act and mail fraud | [13] |
| Victor Fajardo-Velez | Secretary of the Puerto Rico Department of Education | Hobbs Act | [14] |
| José Granados | Speaker of the Puerto Rico House of Representatives | [15] | |
| Héctor Martínez Maldonado | Puerto Rico senator | Program bribery | [16] |
| Edison Misla Aldarondo | Speaker of the Puerto Rico House of Representatives | Hobbs Act | [17] |
| Angel E. Rodriguez-Cabrera | Mayor of Toa Alta, Puerto Rico | Program bribery | [18] |
| José G. Tormos Vega | Mayor of Ponce, Puerto Rico | Hobbs Act | [19] |
| Freddy Valentín | Puerto Rico senator | Hobbs Act | [20] |
The Domestic Violence Offender Gun Ban, often called the "Lautenberg Amendment", is an amendment to the Omnibus Consolidated Appropriations Act of 1997, enacted by the 104th United States Congress in 1996, which bans access to firearms by people convicted of crimes of domestic violence. The act is often referred to as "the Lautenberg Amendment" after its sponsor, Senator Frank Lautenberg. Lautenberg proposed the amendment after a decision from the United States Court of Appeals for the Ninth Circuit, involving underenforcement of domestic violence laws brought under the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution. President Bill Clinton signed the law as part of the Omnibus Appropriations Act of 1997.
The Hobbs Act, named after United States Representative Sam Hobbs (D-AL) and codified at 18 U.S.C. § 1951, is a US federal law enacted in 1946 that provides:
(a) Whoever in any way or degree obstructs, delays, or affects commerce or the movement of any article or commodity in commerce, by robbery or extortion or attempts or conspires to do so, commits, or threatens physical violence to any person or property in furtherance of a plan or purpose to do anything in violation of this section shall be fined under this title or imprisoned not more than twenty years, or both.
United States v. Rodriquez, 553 U.S. 377 (2008), was a United States Supreme Court case interpreting the Armed Career Criminal Act. Justice Samuel Alito, writing for the 6–3 majority, ruled that although the elements of a crime may not be considered "serious," sentence enhancements related to a defendant's prior record will bear on how the determination is made.
Chambers v. United States, 555 U.S. 122 (2009), was a case in which the Supreme Court of the United States held that failing to report for incarceration does not qualify as a "violent felony" for the purposes of the Armed Career Criminal Act.
Honest services fraud is a crime defined in 18 U.S.C. § 1346, added by the United States Congress in 1988, which states "For the purposes of this chapter, the term scheme or artifice to defraud includes a scheme or artifice to deprive another of the intangible right of honest services."
United States v. Nosal, 676 F.3d 854 was a United States Court of Appeals for the Ninth Circuit decision dealing with the scope of criminal prosecutions of former employees under the Computer Fraud and Abuse Act (CFAA). The Ninth Circuit's first ruling established that employees have not "exceeded authorization" for the purposes of the CFAA if they access a computer in a manner that violates the company's computer use policies—if they are authorized to access the computer and do not circumvent any protection mechanisms.
Several statutes, mostly codified in Title 18 of the United States Code, provide for federal prosecution of public corruption in the United States. Federal prosecutions of public corruption under the Hobbs Act, the mail and wire fraud statutes, including the honest services fraud provision, the Travel Act, and the Racketeer Influenced and Corrupt Organizations Act (RICO) began in the 1970s. "Although none of these statutes was enacted in order to prosecute official corruption, each has been interpreted to provide a means to do so." The federal official bribery and gratuity statute, 18 U.S.C. § 201, the Foreign Corrupt Practices Act (FCPA) 15 U.S.C. § 78dd, and the federal program bribery statute, 18 U.S.C. § 666 directly address public corruption.
The Travel Act or International Travel Act of 1961, 18 U.S.C. § 1952, is a Federal criminal statute which forbids the use of the U.S. mail, or interstate or foreign travel, for the purpose of engaging in certain specified criminal acts.
Theft or bribery concerning programs receiving federal funds is a federal crime under 18 U.S.C. § 666. The purpose of this statute is protect the integrity of the vast sums of money distributed through federal programs. The section is designed to facilitate the prosecution of persons who steal money or otherwise divert property or services from state and local governments or private organizations—for example, universities, foundations and business corporations—that receive large amounts of federal funds.
Schmuck v. United States, 489 U.S. 705 (1989), is a United States Supreme Court decision on criminal law and procedure. By a 5–4 margin it upheld the mail fraud conviction of an Illinois man and resolved a conflict among the appellate circuits over which test to use to determine if a defendant was entitled to a jury instruction allowing conviction on a lesser included charge. Justice Harry Blackmun wrote for the majority; Antonin Scalia for the dissent.
United States v. Vampire Nation, 451 F.3d 189, is a 2006 decision of the United States Court of Appeals for the Third Circuit regarding the Federal Sentencing Guidelines and asset forfeiture. A three-judge panel unanimously affirmed the conviction and sentence of Frederick Banks, a Pittsburgh man, on numerous felony charges resulting from fraudulent schemes carried out over the Internet. The case takes its title, which has been singled out as memorable and included among lists of amusingly titled cases, from one of Banks' aliases, an electronic music group of which he was the sole regular member. He had filed the appeal under that name while representing himself.
United States v. Antelope, 430 U.S. 641 (1977), was a United States Supreme Court case in which the Court held that American Indians convicted on reservation land were not deprived of the equal protection of the laws; (a) the federal criminal statutes are not based on impermissible racial classifications but on political membership in an Indian tribe or nation; and (b) the challenged statutes do not violate equal protection. Indians or non-Indians can be charged with first-degree murder committed in a federal enclave.
Ocasio v. United States, 578 U.S. ___ (2016), was a United States Supreme Court case in which the Court clarified whether the Hobbs Act's definition of conspiracy to commit extortion only includes attempts to acquire property from someone who is not a member of the conspiracy. The case arose when Samuel Ocasio, a former Baltimore, Maryland police officer, was indicted for participating in a kickback scheme with an automobile repair shop where officers would refer drivers of damaged vehicles to the shop in exchange for cash payments. Ocasio argued that he should not be found guilty of conspiring to commit extortion because the only property that was exchanged in the scheme was transferred from one member of the conspiracy to another, and an individual cannot be found guilty of conspiring to extort a co-conspirator.
McDonnell v. United States, 579 U.S. ___ (2016), was a United States Supreme Court case concerning the appeal of former Virginia Governor Robert F. McDonnell's conviction under the Hobbs Act. At issue on appeal was whether the definition of "official act" within the federal bribery statutes encompassed the actions for which McDonnell had been convicted and whether the jury had been properly instructed on this definition at trial.
Particularly serious crime in the Immigration and Nationality Act (INA) of the United States is a predecessor of the current aggravated felony. The term "particularly serious crime" was coined for the first time when the U.S. Congress enacted the Refugee Act in 1980. As of September 30, 1996, an aggravated felony conviction with at least 1 year of imprisonment that was actually imposed by a court of law could qualify as a particularly serious crime in certain cases. This requires a case-by-case analysis. An offense that involves murder or torture is considered a particularly serious crime even if the possible term of imprisonment is 2 years or less.
United States v. Sineneng-Smith, 590 U.S. ___ (2020), was a case of the United States Supreme Court, in which the justices considered the constitutionality of 8 U.S.C. § 1324(a)(1)(A)(iv), a provision of the Immigration and Nationality Act of 1952 that criminalizes encouraging or inducing illegal immigration. The case attracted attention from civil liberties groups and immigration advocates, including the American Civil Liberties Union, the Immigrant Defense Project, and the National Lawyers Guild.
Mont v. United States, No. 17-8995, 587 U.S. ___ (2019), is a United States Supreme Court case concerning the proper interpretation of "supervised release" under 18 U.S.C. §3624(e). The case involved a prisoner who was convicted on drug distribution charges and was sentenced to imprisonment and supervised release. While on supervised release, he was charged and pleaded guilty to various state-law offenses, but due to administrative delays, his sentence was not entered until after the day on which his supervised release was to end. He was nonetheless charged with violating the terms of his supervised release, and he sought to challenge the court's jurisdiction to hear the case, arguing that his pretrial detention for the later offenses. The question in the case was whether a term of supervised release for one event can be tolled (paused) by imprisonment for another offense.