United States v. Rowland, No. 15-985 (2d Cir. 2016)
Annotate this CaseDefendant John G. Rowland, the former governor of Connecticut, appealed his conviction of seven counts of violating campaign-finance laws and falsifying records. The court concluded that the broad language of 18 U.S.C. 1519 encompasses the creation of 18 documents - like the contracts at issue here - that misrepresent the true nature of the parties’ negotiations, when the documents are created in order to frustrate a possible future government investigation; the court rejected defendant's assertion that principles of contract law prevent the court from concluding that documents styled as contracts are “falsified” within the meaning of the statute; the court determined that the government adequately disclosed Lisa Wilson‐Foley’s statements to defendant, and that even if it did not, he is not able to show that he was prejudiced by the deficiency; and the court rejected defendant's challenges to the District Court’s other rulings at trial and at sentencing.
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