United States v. Tillmon (P)

After being caught in a sting operation aimed at exposing corrupt law enforcement officers, the defendant-appellant was convicted for multiple drug-trafficking offenses and three counts of federal programs bribery. The challenged drug convictions are affirmed, but the federal-programs bribery convictions must be vacated.

The government failed to produce evidence that the defendant’s services to a drug-trafficking organization had a value of $5,000 or more. There was no evidence other than the amount the defendant was paid as a bribe to establish that the value of his protection services were worth at least $5,000. In the absence of evidence to support that element of the offense, the bribery convictions cannot stand.

Affirmed in part and vacated in part.

United States v. Tillmon (P), No. 17-4648, Feb. 26, 2019. 4th Cir. (Agee) from EDNC at Elizabeth City (Howard).



Categories: 4th U.S. Circuit Court of Appeals, Opinions, Published

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