Ryan v. United States, No. 10-3964 (7th Cir. 2011)
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The former Governor of Illinois, in federal prison following convictions for racketeering, mail fraud, tax evasion, and lying to the FBI, filed a collateral attack (28 U.S.C. 2255) after the Supreme Court held in Skilling v. United States, 130 S. Ct. 2896 (2010), that the honest-services form of the mail-fraud offense (18 U.S.C. 1346) covers only bribery and kickback schemes. The district court dismissed and the Seventh Circuit affirmed, stating that any error was harmless because a reasonable jury could find that Ryan sold his offices to the high bidders.
The court issued a subsequent related opinion or order on August 6, 2012.
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