United States v. Cueto
United States Court of Appeals for the Seventh Circuit
151 F.3d 620 (7th Cir. 1998)
Amiel Cueto (defendant), an attorney with an undisclosed financial stake in a client's illegal video gambling business, filed numerous motions -- some frivolous -- attempting to impede a grand jury investigating that client, Venezia, and continued filing pleadings, an appellate brief, and even a certiorari petition throughout Venezia's prosecution, all nominally in his role as Venezia's defense attorney. All of Cueto's motions to impede the investigation were denied, and he was ultimately convicted of obstruction of justice under the Omnibus Provision of 18 U.S.C. section 1503.
Whether an attorney can be held criminally liable for obstruction of justice under 18 U.S.C. section 1503 for litigation conduct performed in his professional capacity, when that conduct is actually motivated by a corrupt personal interest.