United States v. Medford, No. 08-5030

Decided Nov. 7, 2011

Bobby Lee Medford, a former Sheriff of Buncombe County, NC, was convicted of eleven counts of conspiracy relating to his receipt of bribes in connection with the illegal operation of video poker machines. On appeal, Medford challenged the admission of a recording; the denial of his motion to sever his trial from a co-defendant’s; the sufficiency of the evidence for violation of the Hobbs Act; the Honest Services Fraud statute as unconstitutionally vague; and also asserted that he was deprived of a fair trial.

The Fourth Circuit concluded that any error as to admission of the recording was harmless; Medford did not meet the Parodi factors required to sever a trial; there was no plain error as to his conviction under the Hobbs Act; and that Medford was not deprived of a fair trial. Furthermore, Medford’s contention that the Honest Services Fraud statute is unconstitutionally vague was foreclosed by the Supreme Court’s majority opinion in Skilling. Therefore, the district’s court judgment was affirmed.

Full Opinion

-Sara I. Salehi

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