Sorich v. United States, No. 11-2839 (7th Cir. 2013)
Annotate this Case
Administrators of city agencies were convicted of mail fraud for their roles in a scheme to award Chicago jobs and promotions to favored applicants. They had conducted sham interviews and falsified interview forms. Consistent with case law at the time, the jury was instructed that the defendants were guilty of mail fraud if they deprived the city of money or property, or if they deprived the city of its right to honest services. After the Seventh Circuit affirmed, the Supreme Court ruled in Skilling v. U.S. (2010) that the honest-services fraud statute is limited only to schemes involving bribes or kickbacks. The district court rejected an argument that the defendants are entitled to collateral relief under 28 U.S.C. 2255. The Seventh Circuit affirmed. Although the jury’s receipt of an honest-services theory was error because the scheme did not involve bribes or kickbacks, the error was harmless. The trial reflected a single scheme to take city jobs and promotions through false representations, and these jobs and promotions were the city’s money or property. Any honest-services violation had to be premised on the money/property fraud, and the Skilling error did not have substantial effect on the jury’s verdict.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.