The Third Circuit Court of Appeals upheld former New Jersey State Senator Wayne Bryant’s 2008 political corruption conviction last week, rejecting Bryant’s claims that his due process rights were violated in the case. The court also upheld the conviction of Bryant’s partner in crime, R. Michael Gallagher, the former dean of the University of Medicine and Dentistry of New Jersey (UMDNJ).
For those new to the Third Circuit, Wayne Bryant was convicted on fraud and bribery charges after Gallagher arranged for UMDNJ to pay Bryant $35,000 per year for a low-show job; Bryant, in return, used his position as chairman of the state’s Senate Appropriations Committee to funnel an additional $10 million per year to UMDNJ.
In a second scheme, Bryant used a no-show job as an attorney with the Gloucester County Board of Social Services to increase his state pension.
On appeal, Bryant argued that the government violated his due process rights by interfering with his access to potential witnesses in the pretrial phase of the case, that the evidence of honest services fraud and bribery was insufficient, and that the jury instructions on both honest services fraud and bribery were defective.
The Third Circuit Court of Appeals affirmed Bryant's conviction, finding that there was sufficient evidence to support each of the counts of conviction. The court also ruled that the jury instructions for honest services fraud or bribery were not defective.
Bryant wasn't the only disgraced politician to lose in the Third Circuit last week. On August 24, the court was equally hard on former Pennsylvania State Senator Vincent Fumo. Finding that a federal district judge had committed numerous procedural errors in sentencing Fumo to only 55 months in prison - as opposed to the suggested 180-months' sentence - the court remanded Fumo's case to the district court for resentencing.
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- Cincinnati Public Schools in Voter Bribery Scandal (FindLaw's Law & Daily Life)
- Disgraced Politician to Receive Pension (Fox 25 Boston)