United States v. Rybicki
United States Court of Appeals for the Second Circuit
354 F.3d 124 (2d Cir. 2003)
Relevant factsFree
Thomas Rybicki and Fredric Grae (defendants), attorneys, bribed insurance claims adjusters to expedite settlement of their clients' claims, concealing the payments so the adjusters' employers never learned of the bribes. The defendants were convicted of mail and wire fraud on the theory that they schemed to deprive the insurance companies of their employees' honest services, and they appealed.
IssueFree
Whether the federal mail and wire fraud statutes' prohibition on depriving another of the intangible right to honest services extends to private employment relationships, covering attorneys who secretly bribed insurance adjusters to favor the attorneys' clients.