United States v. Jackson

In light of the U.S. Supreme Court’s 2016 decision in McDonnell v. United States, defendant Vernon Jackson’s 2006 convictions for bribery and conspiracy must be vacated.

In 2006, the defendant pled guilty to bribing and conspiring to bribe a former U.S. Congressman to perform “official acts” for the benefit of the defendant’s company. The defendant seeks a writ of coram nobis on grounds that, under the meaning of “official acts” established in McDonnell, he didn’t plead intelligently during his plea colloquy and there was no factual basis for his guilty plea.

The defendant’s conduct – namely, paying a public official and his family large sums of money in exchange for the official’s promotion of the defendant’s own private business interests – doesn’t fall within the bribery statute under which he was convicted. It’s for Congress to consider whether the law should be clarified so that large payments to public servants, such as those in this case, are within its scope.

Petition granted; convictions vacated.

United States v. Jackson, No. 1:06cr161, Mar. 28, 2019. EDVA at Alexandria (Ellis).

Categories: Opinions, U.S. District Court - Eastern District of Virginia


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