As expected in light of Skilling v. United States, the Second Circuit vacated two convictions for theft of honest services based on Joseph Bruno's failure to disclose alleged conflicts of interest. But the unanimous ruling did not leave the former Senate Majority Leader off the hook, as it found there was sufficient evidence to try Mr. Bruno on an honest services theory alleging actual bribery or kickbacks.
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Bruno Faces Retrial After Panel Vacates Corruption Convictions
New York Law Journal
November 17, 2011
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