List of United States unincorporated territory officials convicted of federal corruption offenses

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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.

Guam[edit]

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]

Northern Marianas Islands[edit]

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]

Puerto Rico[edit]

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]

References[edit]

  1. ^ 18 U.S.C. § 1951(a), (b)(2).
  2. ^ 18 U.S.C. §§ 1341, 1343, 1346.
  3. ^ 18 U.S.C. § 1952.
  4. ^ 18 U.S.C. § 1961(1).
  5. ^ 18 U.S.C. § 666.
  6. ^ Peter W. Schroth, Corruption and Accountability of the Civil Service in the United States, 42 Am. J. Comp. L. 554 (2006).
  7. ^ The en banc Ninth Circuit reversed Aguon's Hobbs Act convictions on the grounds that the Hobbs Act requires inducement, a holding which pre-dated the Supreme Court's decision in Evans v. United States, 504 U.S. 255 (1992). United States v. Aguon, 851 F.2d 1158 (9th Cir. 1988) (en banc).
  8. ^ The Ninth Circuit reversed Gov. Bordallo's program bribery conviction on the grounds that 18 U.S.C. § 666 does not apply to Guam. United States v. Bordallo, 857 F.2d 519, 523–24 (9th Cir. 1988). The Ninth Circuit also reversed Gov. Bordallo's extortion conviction on the grounds that the Hobbs Act requires inducement, a holding which pre-dated the Supreme Court's decision in Evans v. United States, 504 U.S. 255 (1992). Bordallo, 857 F.2d at 527–28.
  9. ^ The Ninth Circuit reversed Soriano's mail fraud conviction in light of the Supreme Court's subsequent decision in McNally v. United States, 483 U.S. 350 (1987). United States v. Soriano, 880 F.2d 192 (9th Cir. 1989).
  10. ^ a b Ferdie de la Torre, Guilty, Saipan Tribune, Apr. 25, 2009.
  11. ^ United States v. Caro-Muniz, 406 F.3d 22 (1st Cir. 2005).
  12. ^ United States v. Cruzado-Laureano, 404 F.3d 470 (1st Cir. 2005).
  13. ^ de Castro Font plead guilty. Pub. Integrity Section, Criminal Division, U.S. Dep't of Justice, Report to Congress on the Activities and Operations of the Public Integrity Section for 2009, at 44.
  14. ^ United States v. Cruz-Mercado, 360 F.3d 30 (1st Cir. 2004).
  15. ^ Granados plead guilty. Pub. Integrity Section, Criminal Division, U.S. Dep't of Justice, Report to Congress on the Activities and Operations of the Public Integrity Section for 2007, at 54–55.
  16. ^ United States v. Bravo-Fernandez, No. 10–232 (FAB), 2011 WL 6145404 (D.P.R. Dec. 12, 2011).
  17. ^ United States v. Misla-Aldarondo, 478 F.3d 52 (1st Cir. 2007).
  18. ^ United States v. Orlando-Figueroa, 229 F.3d 33 (1st Cir. 2000).
  19. ^ United States v. Tormos-Vega, 959 F.2d 1103 (1st Cir. 1992).
  20. ^ Ex-Lawmaker Will Go To Prison, Orlando Sentinel, Oct. 2, 2002.