United States v. Bravo-Fernandez, No. 18-1358 (1st Cir. 2019)Annotate this Case
The First Circuit reversed the convictions of Defendants Juan Bravo-Fernandez and Hector Martinez-Maldonado (Martinez) for federal program bribery, holding that the government did not meet its burden of establishing that the entity Martinez represented as an agent received at least $10,000 in federal “benefits” within the meaning of 18 U.S.C. 666.
In this appeal, the third time this case was before the First Circuit, Defendants argued that evidence stipulated to early in the proceedings was insufficient to convict them of federal program bribery because the government did not introduce evidence sufficient to satisfy the jurisdictional element under section 666(b) that the government entity received “benefits in excess of $10,00 under a Federal program.” The First Circuit agreed, holding that the government failed to meet its burden of establishing that the entity Martinez represented as an agent received the amount of benefits required under section 666(b).