US v. Sawyer

Case Date: 05/30/1996
Court: United States Court of Appeals
Docket No: 95-1689







June 24, 1996 United States Court of Appeals United States Court of Appeals
For the First Circuit For the First Circuit
____________________

No. 95-1689

UNITED STATES,

Appellee,

v.

F. WILLIAM SAWYER,

Defendant, Appellant.

____________________

APPEAL FROM THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS

[Hon. Nathaniel M. Gorton, U.S. District Judge] ___________________

____________________

Before

Boudin, Circuit Judge, _____________
Aldrich, Senior Circuit Judge, ____________________
and Stahl, Circuit Judge. _____________

____________________

ERRATA SHEET ERRATA SHEET

The opinion of this Court issued on May 30, 1996, is amended
as follows:

Page 35, line 4 - change "is" to "in"






























United States Court of Appeals United States Court of Appeals
For the First Circuit For the First Circuit
____________________

No. 95-1689

UNITED STATES,

Appellee,

v.

F. WILLIAM SAWYER,

Defendant, Appellant.

____________________

APPEAL FROM THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS

[Hon. Nathaniel M. Gorton, U.S. District Judge] ___________________

____________________

Before

Boudin, Circuit Judge, _____________
Aldrich, Senior Circuit Judge, ____________________
and Stahl, Circuit Judge. _____________

____________________

Thomas R. Kiley, with whom Carl Valvo, Steven H. Goldberg, _________________ ___________ ___________________
Matthew L. Schemmel, and Cosgrove, Eisenberg & Kiley, P.C., were on ____________________ ___________________________________
brief for appellant.
Timothy W. Jenkins, Gary C. Adler, and O'Connor & Hannan, L.L.P., __________________ _____________ _________________________
were on brief for State Government Affairs Council, amicus curiae.
Ralph D. Gants, Susan Murphy, and Palmer & Dodge, were on brief ______________ ____________ _______________
for The Massachusetts Association of Professional Lobbyists, amicus
curiae.
Michael Kendall, Assistant United States Attorney, with whom ________________
Jonathan Chiel, Acting United States Attorney, and Amy Lederer, _______________ ____________
Assistant United States Attorney, were on brief for appellee.

_____________________
May 30, 1996
_____________________
















STAHL, Circuit Judge. Appellant F. William Sawyer STAHL, Circuit Judge. _____________

appeals his convictions for mail and wire fraud, interstate

travel to commit bribery, and conspiracy to commit those

offenses. The district court imposed a $10,000 fine, and

sentenced him to imprisonment for twelve months and one day.

In this appeal, Sawyer claims that the district court erred

in its jury instructions and in evidentiary rulings, and that

the evidence was insufficient to establish his guilt beyond a

reasonable doubt. For the reasons that follow, we vacate the

convictions and remand for further proceedings.

I. I. __

Facts Facts _____

Viewing the record in the light most favorable to

the verdict, United States v. Wihbey, 75 F.3d 761, 764 (1st _____________ ______

Cir. 1996), a rational jury could have found the following

facts from the trial evidence.

During the indictment period, 1986 to March 1993,

the John Hancock Mutual Life Insurance Company ("Hancock")

employed the defendant-appellant, F. William Sawyer, as a

senior lobbyist within its Government Relations Department.

As the largest life insurance company in Massachusetts,

Hancock had a continuing and abiding interest in the state's

insurance laws. Sawyer's job was to lobby the Massachusetts

Legislature on Hancock's behalf. In particular, his job

description required him to: research and develop Hancock's



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position on pertinent legislation; communicate relevant

information to representative government officials in order

to effect a favorable outcome and to protect the Company's

interests; and establish and maintain relationships with

legislators as well as with members of industry associations.

A principal focus of Sawyer's lobbying activities

was the Legislature's Joint Insurance Committee ("Insurance

Committee"), composed of state representatives and senators.

The Insurance Committee has the ability to impact life

insurance regulations more than any other legislative

committee. To this end, it reviews approximately 300 bills

per year, about fifty of which affect the life insurance

industry. During each year of the indictment period,

Massachusetts life insurance companies actively sought the

passage of about five bills, most of which made it

successfully through the Insurance Committee "in some form or

another." Robert J. Smith, a research analyst and director

for the Committee, testified that, during the indictment

period, Sawyer was one of three lobbyists who appeared most

often to lobby for bills sought by the life insurance

industry.

The Insurance Committee is co-chaired by a senate

and house member, each with equal control over the fate of

bills assigned to the Committee. The Chairs have the ability

to schedule hearings, assign bills to the hearing calendar



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and subsequent executive sessions, advocate bills at

executive sessions, and take other action to advance them

through the Committee. Each Chair could "carry" a bill,

i.e., actively guide it through the Legislature as a whole; ____

alternatively, a Chair could send it to the "Study Committee"

which usually shelved it.

During the indictment period, Sawyer focused his

lobbying activities on the house members of the Insurance

Committee, some of whom took action that directly or

indirectly affected Hancock's interests. Representative

Francis H. Woodward was the House Chair of the Insurance

Committee from 1986 to 1990. Research analyst Smith

identified Sawyer as the lobbyist he saw most often with

Representative Woodward during Woodward's tenure as the

Committee's House Chair. During this time, the Insurance

Committee never rejected Woodward's recommendations on bills

affecting the life insurance industry and Woodward "carried"

most of the bills sought by the industry. Representative

Frank Emilio, a member from 1986 to 1990, sponsored a

September 1990 bill on behalf of Hancock. Representative

John F. Cox sponsored bills that Hancock supported in

November 1990 and December 1991. In addition,

Representatives Walsh, Mara, and Driscoll sponsored

legislation sought by the life insurance industry.





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"Legislative Reports" issued by the Hancock

Government Relations Department to senior Hancock officers,

and signed by Sawyer, outlined specific lobbying efforts and

proceedings in the Massachusetts Legislature pertinent to

Hancock's interests. In July 1990, Sawyer wrote a memorandum

to Hancock's Management Committee summarizing the successful

efforts of Hancock lobbyists, including himself, in excluding

Hancock from a bill that would have subjected it to a $100-

million tax liability. In a September 1990 memorandum to the

Management Committee, Sawyer referred to a 1990 bill, filed

by Representative Emilio, that allowed Hancock to assess and

report its real estate advantageously. A November 1990

letter from Ralph F. Scott, Hancock's Assistant Legislative

Counsel, to Representative Cox indicated that Sawyer and

Scott planned to work with Cox in obtaining favorable action

on a specific bill that he had sponsored for Hancock.

During the indictment period, Sawyer paid for

numerous meals, rounds of golf, and other entertainment for

and with Massachusetts legislators, including many members of

the Insurance Committee. Although Sawyer initially paid for

most of these activities himself, they were treated as

business expenses and reimbursed by Hancock (hereinafter

"expenditures"). In accordance with Hancock's procedures,

Sawyer would complete monthly expense vouchers, attaching

receipts and a handwritten calendar that identified the



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recipients of the expenses. Sawyer's supervisor, Raeburn B.

Hathaway, the head of Hancock's Government Relations

Department, reviewed Sawyer's expense vouchers and approved

them for reimbursement. Hathaway's secretary would then

detach the detailed calendars from the vouchers, keeping the

calendars within the Government Relations Department, and

forward the voucher, alone, to the accounting department for

payment.

Analysis of Sawyer's expense vouchers and calendars

during the indictment period revealed that the top three

recipients of his expenditures were: Representative Woodward,

who received more than $8,000 worth of expenditures during

his tenure as Insurance Committee House Chair; Robert

Howarth, an Insurance Committee member from 1986 to 1992

(over $3,000); and Representative Emilio (over $2,500).

After these three legislators left office, Sawyer, on behalf

of Hancock, expended practically nothing on entertaining them

(Woodward, $0; Howarth, $8.33; and Emilio, $85.65).

Specifically, Sawyer's expenditures included

thousands of dollars for golf -- in and out of state -- with

various Massachusetts legislators including Representative

Francis Mara, Woodward's 1991 successor as Insurance

Committee House Chair. Sawyer also hosted dinners for

legislators and their families. In September 1992, Sawyer

provided Representative Mara and his wife tickets for a show



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in Hancock's private box at the Wang Center and ordered an

accompanying dinner.

The apparent catalyst for this prosecution was a

December 1992 trip to Puerto Rico where Sawyer, other

lobbyists, and a group of legislators, including

Representative Mara, travelled for a legislative conference.

The group did not stay at the conference site, but instead

went to a different resort where Sawyer paid for many of the

legislators' meals, transportation, and golf. Hancock

reimbursed Sawyer for some $4,000 of entertainment expenses

from the Puerto Rican trip.1

Both Sawyer and his supervisor, Hathaway, had

reason to believe that these expenditures could or did

violate certain state laws. In his office, Sawyer kept

internal Hancock memoranda, newspaper articles, and opinions

of the Massachusetts Ethics Commission, all explaining or

reporting on Massachusetts ethics-in-lobbying. While some of

the documents varied in their interpretations, they




____________________

1. In 1986, Sawyer and his wife travelled with
Representative Woodward and his wife to New Orleans for the
Super Bowl. Hancock provided the game tickets and reimbursed
Sawyer for the airfare. The district court instructed the
jury that, because this trip occurred before the mail fraud
statute proscribed honest services fraud, it could not
provide the sole basis for a mail fraud conviction. The
court added, however, that the jury could consider the trip
as evidence of Sawyer's state of mind with respect to the
alleged scheme to defraud.

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nonetheless advised on compliance with laws regarding

gratuities, gifts, and lobbying expenditures.

In April 1993, a reporter from the Boston Globe

newspaper queried Richard Bevilacqua, Hancock's Director of

Employee and Customer Communications, about Sawyer's

entertainment of legislators during the 1992 Puerto Rico trip

and about Hancock's legislative agenda during that period.

Bevilacqua, in turn, asked Sawyer about the trip, and Sawyer

opined, "it's difficult to take anyone out to lunch or dinner

these days without going over [the] amount [permitted by

law]." This set of events prompted Hancock to begin an

internal investigation into Sawyer's legislative

expenditures.2 Bruce A. Skrine, vice president, corporate

counsel and secretary for Hancock, asked Sawyer for his

expense records. Contemporaneous with Sawyer's production of

the records, Sawyer told Skrine that the expenses were

"consistent with the way . . . things were done on Beacon

Hill." Sawyer also told Skrine that his reason for making

the expenditures was "to get to know" the legislators and to

develop "a certain relationship so that you could turn to


____________________

2. In the Spring of 1993, the United States Attorney's
Office for the District of Massachusetts ("USAO") commenced
an investigation into Hancock's involvement in the allegedly
illegal expenditures on legislators. In March 1994, Hancock
entered into a civil settlement with the USAO whereby it paid
a fine of about $1,000,000 and promised to cooperate with the
USAO. In return, the USAO agreed not to prosecute Hancock
for any matter relating to the investigation.

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them"; he further indicated that he made these expenditures

to "build and maintain relationships," gain "access to

legislators," and get legislators to "return his calls as a

result of [the expenditures]."

Sawyer caused the mailing of items related to the

expenditures on legislators, including golf bills,

reimbursement requests, and credit card bills. Sawyer also

caused the making of interstate telephone calls to arrange

for some of the entertainment.

Following a nine-day trial, the jury convicted

Sawyer of fifteen counts of mail fraud, nine counts of wire

fraud, eight counts of interstate travel to commit bribery,

and one count of conspiracy. The jury acquitted Sawyer of

two additional mail fraud counts.

II. II. ___

Mail and Wire Fraud Counts Mail and Wire Fraud Counts __________________________

The government charged that Sawyer and his

unindicted co-conspirator -- his Hancock supervisor, Hathaway

-- engaged in a scheme to deprive the Commonwealth of

Massachusetts and its citizens of the right to the honest

services of their state legislators,3 and used the mails and

____________________

3. According to the indictment, the legislators' duty of
honest services included the obligation to perform their jobs
as Massachusetts lawmakers free from deceit, fraud,
dishonesty, favoritism and self-enrichment. By consent of
the parties, the district court struck the word "favoritism"
in this description. United States v. Sawyer, 878 F. Supp. _____________ ______
279, 294 (D. Mass. 1995). In addition to this general duty

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interstate telephone wires in furtherance of the scheme, in

violation of 18 U.S.C. 1341, and 1343.4

Sawyer contends that his convictions impermissibly

involve the federal government in setting standards of good

government for local and state officials. He argues that

this case is exemplary of the "dangers of standardless

federal criminal enforcement and unbridled prosecutorial

discretion long-recognized under the mail fraud statute." We

have already considered and rejected these arguments,


____________________

of honest services, the indictment stated that the
legislators had a specific duty to abide by the Massachusetts
laws set forth in the indictment. The indictment identified
both the Commonwealth of Massachusetts and its citizenry as
the fraud victims; for simplicity, we will refer only to the
public (or "citizenry") as the victim.
With regard to the scheme to defraud, the
indictment charged, inter alia, that Sawyer gave, and _____ ____
legislators accepted, travel, lodging, golf, meals and other
entertainment in violation of Massachusetts law; that Sawyer
monitored the public coverage of the Massachusetts
Legislature so that he could ensure the nondisclosure of his
gratuities; that Sawyer was given greater access to the
Insurance Committee and its House Chair than was available
generally to the citizenry; that the House Chair of the
Insurance Committee repeatedly performed official acts
advocated by Sawyer on behalf of Hancock; and that Sawyer's
direct supervisor approved of, and authorized Hancock's
reimbursement of Sawyer for, his illegal gratuities.

4. In relevant part, 18 U.S.C. 1341 and 1343 provide:

Whoever, having devised or intending to
devise any scheme or artifice to defraud,
or for obtaining money or property by
means of false or fraudulent pretenses,
representations, or promises . . . [uses
the mails or wires, or causes their use]
for the purpose of executing such scheme
or artifice . . . [shall be punished].

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however. See United States v. Silvano, 812 F.2d 754, 758-59 ___ _____________ _______

(1st Cir. 1987). Congress may protect the integrity of the

interstate mails and wires by forbidding their use in

furtherance of schemes to defraud a state and its citizens,

whether or not it can forbid the scheme itself. See id. at ___ ___

758 (citing Badders v. United States, 240 U.S. 391, 393 _______ _____________

(1916)); United States v. Rendini, 738 F.2d 530, 533 (1st ______________ _______

Cir. 1984).5

Sawyer also contends that the government has failed

to establish that he committed "honest services" mail and

wire fraud ("honest services fraud") within the meaning of

the statutes. To explain our resolution of this issue, we

provide a brief overview of the law of honest services fraud.

The ultimate issue is whether or not the "scheme" presented

at trial actually targeted the Massachusetts' citizens' right




____________________

5. Some have observed that these statutes are increasingly
used effectively to convict and punish for the substantive
fraud, and that the use of the mails or wires is merely a
"jurisdictional hook" to bring the conduct within the
proscription of the mail and wire fraud statutes. See Peter ___
J. Henning, Maybe It Should Just Be Called Federal Fraud: The _________________________________________________
Changing Nature of the Mail Fraud Statute, 36 B.C. L. Rev. ___________________________________________
435 (1995); cf. Schmuck v. United States, 489 U.S. 705, 722- ___ _______ _____________
23 (1989) (Scalia, J. dissenting) (disagreeing with
majority's conclusion that certain mailings were in
furtherance of the demonstrated scheme, and observing that
"[t]he law does not establish a general federal remedy
against fraudulent conduct, with the use of the mails as the
jurisdictional hook . . . . In other words, it is mail fraud,
not mail and fraud, that incurs liability." (internal
citations, quotations and alterations omitted)).

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to "honest services" within the meaning of the mail fraud

statute.

To prove mail and wire fraud, the government must

prove, beyond a reasonable doubt: (1) the defendant's knowing

and willing participation in a scheme or artifice to defraud

with the specific intent to defraud, and (2) the use of the

mails or interstate wire communications in furtherance of the

scheme.6 United States v. Montminy, 936 F.2d 626, 627 (1st _____________ ________

Cir. 1991) (listing mail fraud elements); United States v. ______________

Cassiere, 4 F.3d 1006, 1011 (1st Cir. 1993) (listing wire ________

fraud elements). Because the relevant language in both the

mail and wire fraud statutes is the same, we analyze both

offenses together for the purposes of this case and, for

simplicity, we refer only to mail fraud. See United States ___ _____________

v. Boots, 80 F.3d 580, 586 n.11 (1st Cir. 1996). _____

Traditionally, the mail fraud statute reached

schemes that deprived the fraud victim of property or some

other item of economic value. See generally, United States ___ _________ ______________

v. Grandmaison, 77 F.3d 555, 565-66 (1st Cir. 1996). Some ___________

courts later expanded the scope of the statutes to encompass

schemes intended to defraud citizens of their intangible,

____________________

6. The use of the mails or wires to further the fraudulent
scheme need only be "incidental." United States v. ______________
Grandmaison, 77 F.3d 555, 566 (1st Cir. 1996). Moreover, the ___________
"[d]efendant[] need not personally use the [mails or] wires
as long as such use was a reasonably foreseeable part of the
scheme in which [he] participated." United States v. Boots, _____________ _____
80 F.3d 580, 585 n.8 (1st Cir. 1996).

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non-property right to the honest services of their public

officials. See generally, W. Robert Gray, Comment, The ___ _________ ___

Intangible-Rights Doctrine and Political-Corruption _____________________________________________________________

Prosecutions Under the Federal Mail Fraud Statute, 47 U. Chi. __________________________________________________

L. Rev. 562, 563 (1980) and cases cited therein. Those

courts rationalized that a public official "acts as `trustee

for the citizens and the State . . . and thus owes the normal

fiduciary duties of a trustee, e.g., honesty and loyalty' to ____

them." Silvano, 812 F.2d at 759 (quoting United States v. _______ _____________

Mandel, 591 F.2d 1347, 1363 (4th Cir.), aff'd in relevant ______ _________________

part en banc, 602 F.2d 653, 653 (4th Cir. 1979), cert. _____________ _____

denied, 445 U.S. 961 (1980)). ______

In 1987, the United States Supreme Court held,

contrary to every circuit court that had decided the issue,

that the mail fraud statute did not prohibit schemes to

defraud citizens of their intangible, non-property right to

honest and impartial government. McNally v. United States, _______ _____________

483 U.S. 350, 359 (1987); see United States v. Ochs, 842 F.2d ___ _____________ ____

515, 521 (1st Cir. 1988) (noting Court's unexpected

decision), cert. denied, 498 U.S. 895 (1990). Congress _____ ______

quickly reacted to the McNally decision by enacting 18 U.S.C. _______

1346, which provides that, for the purposes of, inter alia, _____ ____

the mail and wire fraud statutes, "the term `scheme or

artifice to defraud' includes a scheme or artifice to deprive

another of the intangible right of honest services." We have



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recognized that 1346 was intended to overturn McNally and _______

reinstate the reasoning of pre-McNally case law holding that _______

the mail fraud statute reached schemes to defraud individuals

of the intangible right to honest services of government

officials. See Grandmaison, 77 F.3d at 565-66.7 ___ ___________

The concept of governmental "honest services" in

this context eludes easy definition. As Judge Winter has

aptly noted:

One searches in vain for even the vaguest
contours of the legal obligations created
beyond the obligation to conduct
governmental affairs "honestly" or
"impartially," to ensure one's "honest
and faithful participation" in government
and to obey "accepted standards of moral
uprightness, fundamental honesty, fair
play and right dealing" . . . . (citation
omitted) [T]he quest for legal standards
is not furthered by reference to "the
right to good government" and the duty
"to act in a disinterested manner."



____________________

7. See also 134 Cong. Rec. H11108-01, 1988 WL 182261 (Oct. ___ ____
21, 1988) (statement of Rep. Conyers) ("This amendment is
intended merely to overturn the McNally decision. No other _______
change in the law is intended."); 134 Cong. Rec. S17360-02,
1988 WL 182529 (Nov. 10, 1988), Section Analysis of Judiciary
Committee Issues in H.R. 5210, (Statement of Sen. Biden)
("[Section 1346] overturns the decision in McNally . . . . _______
The intent is to reinstate all of the pre-McNally case law _______
pertaining to the mail and wire fraud statutes without
change"). But see United States v. Brumley, 79 F.3d 1430, ___ ___ ______________ _______
1440 (5th Cir. 1996) (holding that 1346 does not clearly
reach schemes to defraud citizens of their right to
government officials' honest services).
Given the peculiar history and evolution of
honest-services mail fraud, we review case law from before
and after the McNally decision for guidance in discerning the _______
parameters of this federal crime.

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United States v. Margiotta, 688 F.2d 108, 142-143 (2d Cir. _____________ _________

1982) (Winter, J., concurring in part and dissenting in part)

(quoting Mandel, 591 F.2d at 1361), cert. denied, 461 U.S. ______ _____ ______

913 (1983).

The cases in which a deprivation of an official's

honest services is found typically involve either bribery of

the official or her failure to disclose a conflict of

interest, resulting in personal gain. In a leading case

involving the bribery of a state governor on legislative

matters, the Fourth Circuit explained how bribery of an

official can constitute honest services fraud:

[T]he fraud involved in the bribery of a
public official lies in the fact that the
public official is not exercising his
independent judgment in passing on
official matters. . . . When a public
official has been bribed, he breaches his
duty of honest, faithful and
disinterested service. . . . [T]he
official has been paid for his decisions,
perhaps without even considering the
merits of the matter. Thus, the public
is not receiving what it expects and is
entitled to, the public official's honest
and faithful service.

Mandel, 591 F.2d at 1362; see also, Boots, 80 F.3d at 592-94 ______ ___ ____ _____

(involving scheme to bribe Native-American police chief in

exercise of his border patrol duties); United States v. _____________

Holzer, 816 F.2d 304, 308 (7th Cir.) (judge's systematic ______

receipt of bribes and "loans" to influence official actions),

vacated, 484 U.S. 807 (1987) (ordering reconsideration in _______

light of McNally); United States v. Isaacs, 493 F.2d 1124, _______ _____________ ______


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1149-51 (7th Cir.) (public officials received bribes intended

to induce special favors and preferential treatment for

certain racing interests), cert. denied, 417 U.S. 976 (1974). _____ ______

A public official has an affirmative duty to

disclose material information to the public employer. See ___

Silvano 812 F.2d at 759. When an official fails to disclose _______

a personal interest in a matter over which she has decision-

making power, the public is deprived of its right either to

disinterested decision making itself or, as the case may be,

to full disclosure as to the official's potential motivation

behind an official act. See id. (upholding conviction of ___ ___

city fiduciary who failed to disclose material information

about unnecessary spending of city money for secret

enrichment of fiduciary's friend). Thus, undisclosed, biased

decision making for personal gain, whether or not tangible

loss to the public is shown, constitutes a deprivation of

honest services. See e.g., Grandmaison, 77 F.3d at 567 (city ___ ____ ___________

board member took secret action to influence award of public

contract to official's private construction-business

interest); United States v. Waymer, 55 F.3d 564 (11th Cir. _____________ ______

1995) (board of education member received secret commissions

from companies contracting with school system), cert. denied, _____ ______

No. 95-887, 64 U.S.L.W. 3653, 3656 (U.S. May 20, 1996).

The broad scope of the mail fraud statute, however,

does not encompass every instance of official misconduct that



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results in the official's personal gain. For example, in

United States v. McNeive, 536 F.2d 1245, 1246 (8th Cir. _____________ _______

1976), a city plumbing inspector repeatedly accepted

unsolicited gratuities in connection with his non-

discretionary, administrative duty to issue plumbing permits.

Although McNeive may have violated a city ordinance banning

the acceptance of gratuities by city officials, the court

found his conduct beyond the reach of the mail fraud statute

because there was no evidence that the gratuities

disadvantaged the city in any respect or that they deterred

McNeive from otherwise conscientiously performing his duties.

Id. at 1251. In short, the "scheme" was shown to neither ___

involve nor contemplate the deprivation of McNeive's honest

services to the city or public.

Likewise, in United States v. Rabbitt, 583 F.2d _____________ _______

1014, 1026 (8th Cir. 1978), cert. denied, 439 U.S. 1116 _____ ______

(1979), the Eighth Circuit reversed the mail fraud

convictions of Rabbitt, a state representative. Rabbitt had

offered to introduce a friend's architectural firm to certain

public officials responsible for awarding state architectural

contracts, in return for a ten percent commission on any work

awarded. Id. at 1020. The government charged that his ___

receipt of the resulting, undisclosed commissions defrauded

the citizens of Rabbitt's honest services. Id. at 1025. The ___

evidence showed, however, that the officials who awarded the



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architectural contracts did so on merit alone and Rabbitt

played no role in the selection of the firm. Id. at 1026. ___

Because Rabbitt did not control the awarding of the

contracts, or otherwise fail to fulfill his official duties,

his conduct did not deprive the citizens of his honest

services. Id. (noting case's resemblance to McNeive, 536 ___ _______

F.2d at 1251-52). The court also observed that the

government failed to cite any applicable standard requiring

Rabbit to disclose his interest in the contracts, and thus,

the citizens were not deprived of any right to such

disclosure. Id. at 1026. ___

The McNeive and Rabbitt cases illustrate that _______ _______

although a public official might engage in reprehensible

misconduct related to an official position, the conviction of

that official for honest-services fraud cannot stand where

the conduct does not actually deprive the public of its right

to her honest services, and it is not shown to intend that

result. Similarly, if a non-public-official is prosecuted

for scheming to defraud the public of an official's honest

services, the government must prove that the target of the

scheme is the deprivation of the official's honest services.

If the "scheme" does not, as its necessary outcome, deprive

the public of honest services, then independent evidence of

the intent to deprive another of those services must be

presented. See United States v. D'Amato, 39 F.3d, 1249, 1257 ___ _____________ _______



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(2d Cir. 1994) ("Where the scheme does not cause injury to

the alleged victim as its necessary result, the government

must produce evidence independent of the alleged scheme to

show the defendant's fraudulent intent."); United States v. ______________

Von Barta, 635 F.2d 999, 1005-1006 n.14 (2d Cir. 1980) __________

(noting that "the prosecution must prove that some actual

harm or injury was at least contemplated"), cert. denied, 450 _____ ______

U.S. 998 (1981). With this background, we consider the facts

of this case.



































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A. Scheme to Defraud _____________________

Here, the government did not prosecute Sawyer on

the theory that he, as a lobbyist, directly owed a duty of

honest services to the Commonwealth or its citizens. Rather,

the government sought to prove that Sawyer engaged in conduct

intended to cause state legislators to violate their duty to

the public. The government sought to establish this scheme

by proving that Sawyer intentionally violated, or caused

members of the legislature to violate, two Massachusetts

statutes.

Briefly, these two Massachusetts statutes,

discussed more fully infra, are: (1) Mass. Gen. L. ch. 268B, _____

6 (the "gift" statute), which prohibits -- under threat of

civil penalties -- a "legislative agent" from offering or

giving to a public official (or an official's acceptance of)

"gifts" aggregating $100 or more per year; and (2) Mass. Gen.

L. ch. 268A, 3 (the "gratuity" statute), which prohibits --

under threat of civil and criminal penalties -- anyone from

giving to a legislator (or a legislator from soliciting or

accepting) anything of "substantial value . . . for or

because of any official act performed or to be performed" by

that person. Through the violation of these laws, the

government contended, Sawyer stole the honest services of the

legislators.





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In general, proof of a state law violation is not

required for conviction of honest services fraud. See ___

Silvano, 812 F.2d at 759. Indeed, the incorporation of a _______

state law violation in such a prosecution may cause

complications. See United States v. Washington, 688 F.2d ___ _____________ __________

953, 958 (5th Cir. 1982) (reversing mail fraud conviction

where jury should have been instructed that the defendant

"should not be found guilty of the federal offense merely

because he violated state law"). Here, however, the parties

agree that the indictment, as structured, required it to

prove that Sawyer violated at least one state law. Thus, the

state laws in question had to be correctly charged as a

matter of state law, and the violation of at least one had to

be proven.

Sawyer appeals various aspects of the court's jury

instructions on the state statutes and their role in the

alleged scheme to defraud. To determine whether the court's

instructions adequately explained the law or whether they

"tended to confuse or mislead the jury," United States v. _____________

Alzanki, 54 F.3d 994, 1001 (1st Cir. 1995) (internal _______

quotations and citation omitted), cert. denied, 116 S. Ct. _____ ______

909 (1996), we review the entire charge pertaining to the

role of the state statutes in this honest services fraud

prosecution:

In this case the government has charged
Mr. Sawyer with devising a scheme or


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artifice; that is, a plan, to deprive the
Commonwealth of Massachusetts and its
citizens of their right to the honest
services of members of the Massachusetts
Legislature by giving or offering to
those legislators gifts of free travel,
lodging, golf, meals, and other
entertainment. I instruct you that under
the mail and wire fraud statutes, a
scheme to defraud can be a plan to
deprive the public of its right to the
honest services of members of the
Massachusetts Legislature.
Elected public officials, such as
members of the Massachusetts Legislature,
owe certain duties to the Commonwealth of
Massachusetts and to its citizens. One
of those duties is the duty to act
honestly. The government charges that by ______________________________
violating and causing legislators to _________________________________________
violate certain state statutes, Mr. _________________________________________
Sawyer deprived the public of its right _________________________________________
to the honest services of members of the _________________________________________
Massachusetts Legislature and, therefore _________________________________________
devised a scheme to defraud. ___________________________
In other words, the government
alleges that the defendant violated ___________________
federal laws, mail fraud and wire fraud, _________________________________________
by intentionally violating or causing _________________________________________
Massachusetts legislators to violate _________________________________________
certain state laws. Accordingly, in ____________________
order to prove the first element of the
mail fraud and/or wire fraud, that the
defendant devised a scheme to defraud,
the government must prove beyond a
reasonable doubt that the defendant
intentionally violated or caused members
of the Massachusetts Legislature to
violate at least one of the following two
state laws . . . . (emphasis added).

After describing the two statutes, the court continued:

If you find beyond a reasonable doubt
that the defendant devised or created a
scheme to defraud in which he
intentionally violated or caused a
violation of at least one of the laws
that I have just described, then you may
find that the government has proved the


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first element of mail fraud and wire
fraud.

These instructions permitted the jury to find the

requisite scheme to defraud upon proof that Sawyer violated,

or caused legislators to violate, either one of the state ______

statutes. In other words, the jury was allowed to find that

a violation of either statute, without more, constituted the

deprivation of honest services.8 At oral argument before

this court, the government affirmed that it chose the state

law violations as "the sole vehicle to prove the scheme or

artifice to defraud" in order to "narrow the issues of intent

and good faith." Thus, we analyze both state statutes in

light of the law of honest services, set forth above, to

determine whether the court's instructions erroneously

permitted a conviction for conduct not within the reach of

the mail fraud statute.

1. The Gift Statute ____________________


____________________

8. After the court instructed the jury, Sawyer lodged the
following objection:

Your Honor, I believe that the Court's
instruction failed to properly instruct
the jury that, even if it finds that the
defendant violated one of the two state
statutes . . . the defendant would not be
guilty of any federal offense, mail fraud
and wire fraud offense, unless [the
violation] was part of a plan to defraud
the Commonwealth of Massachusetts or its
citizens of the duty of honest services.

The court declined any further charge.

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The first Massachusetts statute on which the

alleged scheme to defraud was based is ch. 268B, 6 (the

"gift statute"), which provides:

No legislative agent shall knowingly and
wilfully offer or give to a public
official or public employee or a member
of such person's immediate family, and no
public official or public employee or
member of such person's immediate family
shall knowingly and wilfully solicit or
accept from any legislative agent, gifts
with an aggregate value of one hundred
dollars or more in a calendar year.

Mass. Gen. L. ch. 268B, 6. We discuss Sawyer's challenges

to the court's instructions on the statutory definitions

before turning to the statute's relation to the scheme to

defraud.

a. "Legislative Agent" _______________________

The court instructed the jury that, under the

statute, a legislative agent cannot give or offer gifts

aggregating $100 or more to a legislator or member of the

legislator's family. It further instructed that a

"legislative agent" is "any person who, for compensation or

reward, does any act to promote, oppose or influence

legislation." See Mass. Gen. L. ch. 268B, 1(g).9 Sawyer ___

____________________

9. The entire definition of "legislative agent," for
purposes of the gift statute, is:

any person who for compensation or reward
does any act to promote, oppose or
influence legislation . . . . The term
shall include persons who, as any part of
their regular and usual employment and

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argues that this instruction failed to reflect his assertion

that a person is a "legislative agent" only when he is so

registered with the Secretary of State or he is actually

engaging in lobbying activity at the time he gave the alleged

gifts.

The court instructed that a legislative agent is

one who is paid to "promote, oppose or influence

legislation," i.e., to lobby, and that such agents are ____

forbidden to