List of United States unincorporated territory officials convicted of federal corruption offenses

This is a list of notable United States unincorporated territory officials convicted of federal public corruption offenses for conduct while in office. The list is organized by office. Non-notable officials, such as sewer inspectors and zoning commissioners, are not included on this list, although they are routinely prosecuted for the same offenses. Acquitted officials are not listed (if an official was acquitted on some counts, and convicted on others, the counts of conviction are listed). Officials convicted of territorial crimes are not listed.

The criminal statute(s) under which the conviction(s) were obtained are noted. If a defendant is convicted of a conspiracy to commit a corruption offense, the substantive offense is listed. Convictions of non-corruption offenses, such as making false statements, perjury, obstruction of justice, electoral fraud, and campaign finance regulations, even if related, are not noted. Nor are derivative convictions, such as tax evasion or money laundering. Officials convicted only of non-corruption offenses are not included on this list, even if indicted on corruption offenses as well. Certain details, including post-conviction relief, if applicable, are included in footnotes.

The Hobbs Act (enacted 1934),18 U.S.C. § 1951(a), (b)(2). the mail and wire fraud statutes (enacted 1872), including the honest services fraud provision,18 U.S.C. §§ 1341, 1343, 1346. the Travel Act (enacted 1961),18 U.S.C. § 1952. the Racketeer Influenced and Corrupt Organizations Act (RICO) (enacted 1970),18 U.S.C. § 1961(1). and the federal program bribery statute, 18 U.S.C. § 666 (enacted 1984),18 U.S.C. § 666. have been used to prosecute of such officials. These statutes are also applicable to corrupt federal, state, and local officials.Peter W. Schroth, Corruption and Accountability of the Civil Service in the United States, 42 554 (2006). The Ninth Circuit has held that the program bribery statute does not apply to Guam.

Guam OfficialOfficeCrime(s)NotesDirector of the Department of Education of GuamHobbs ActThe en banc Ninth Circuit reversed Aguon's Hobbs Act convictions on the grounds that the Hobbs Act requires inducement, a holding which pre-dated the Supreme Court's decision in Evans v. United States, 504 U.S. 255 (1992). United States v. Aguon, 851 F.2d 1158 (9th Cir. 1988) (en banc).Governor of GuamHobbs Act and program briberyThe Ninth Circuit reversed Gov. Bordallo's program bribery conviction on the grounds that 18 U.S.C. § 666 does not apply to Guam. United States v. Bordallo, 857 F.2d 519, 523–24 (9th Cir. 1988). The Ninth Circuit also reversed Gov. Bordallo's extortion conviction on the grounds that the Hobbs Act requires inducement, a holding which pre-dated the Supreme Court's decision in Evans v. United States, 504 U.S. 255 (1992). Bordallo, 857 F.2d at 527–28.Director of the Department of Parks and Recreation of GuamHobbs Act and mail fraudThe Ninth Circuit reversed Soriano's mail fraud conviction in light of the Supreme Court's subsequent decision in McNally v. United States, 483 U.S. 350 (1987). United States v. Soriano, 880 F.2d 192 (9th Cir. 1989).

Northern Marianas Islands

OfficialOfficeCrime(s)NotesWire fraud, program bribery, and conspiracy to defraud the United StatesWire fraud, program bribery, and conspiracy to defraud the United StatesFerdie de la Torre, Guilty , , Apr. 25, 2009.

Puerto Rico

OfficialOfficeCrime(s)NotesMayor of Rincón, Puerto RicoProgram briberyUnited States v. Caro-Muniz, 406 F.3d 22 (1st Cir. 2005).Mayor of Vega Alta, Puerto RicoHobbs Act and program briberyUnited States v. Cruzado-Laureano, 404 F.3d 470 (1st Cir. 2005).Puerto Rico senatorHobbs Act and mail fraudde Castro Font pleaded guilty. , at 44.Secretary of the Puerto Rico Department of EducationHobbs ActUnited States v. Cruz-Mercado, 360 F.3d 30 (1st Cir. 2004).Speaker of the Puerto Rico House of RepresentativesGranados pleaded guilty. , at 54–55.Puerto Rico senatorProgram briberyUnited States v. Bravo-Fernandez, No. 10–232 (FAB), 2011 WL 6145404 (D.P.R. Dec. 12, 2011).Speaker of the Puerto Rico House of RepresentativesHobbs ActUnited States v. Misla-Aldarondo, 478 F.3d 52 (1st Cir. 2007).Mayor of Toa Alta, Puerto RicoProgram briberyUnited States v. Orlando-Figueroa, 229 F.3d 33 (1st Cir. 2000).Mayor of Ponce, Puerto RicoHobbs ActUnited States v. Tormos-Vega, 959 F.2d 1103 (1st Cir. 1992).Puerto Rico senatorHobbs ActEx-Lawmaker Will Go To Prison, , Oct. 2, 2002.

See also List of federal political scandals in the United States

References