US v. Condron, No. 23-1032 (1st Cir. 2024)
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In the case at hand, the defendant, Christopher Condron, was convicted of wire fraud and conspiracy to defraud the United States by obtaining payment for false claims. He had been involved in submitting applications to the United States Department of the Treasury for grant money in connection with supposed renewable energy projects. The applications were submitted on behalf of four different companies, which were created under the name of his then-girlfriend, Jessica Metivier.
Condron appealed his conviction on three main grounds:
1) He argued that there was insufficient evidence to sustain his conviction on all counts.
2) He claimed that the government's argument and evidence at trial constructively amended, or at least prejudicially varied from, one of the wire fraud counts.
3) He contended that the district court abused its discretion when it limited his cross-examination of a key government witness.
The United States Court of Appeals for the First Circuit rejected all three arguments and affirmed Condron's conviction. It found that there was sufficient evidence to support the conviction, that the government did not constructively amend or prejudicially vary from the indictment, and that the district court did not abuse its discretion in limiting Condron's cross-examination of a key government witness.
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