U.S. v. Whiteagle

Record contained sufficient evidence to support jury’s guilty verdict on charges of bribery and conspiracy to bribe Ho-Chunk Nation legislator in order to secure favorable treatment for three different vendors seeking to do business with said Nation. Although defendant argued that said legislator was unaware of his efforts to extract money from potential vendors, and that defendant had kept all proceeds for himself, record showed existence of series of emails that were copied to legislator, where defendant held himself out as legislator’s agent and demanded cash and other remuneration in exchange for legislator’s action. As such, jury could have concluded that legislator was knowing participant in bribery conspiracy. Dist. Ct. also did not err in admitting false invoices submitted by defendant to vendor, since such evidence was relevant to show means defendant used to mask efforts that defendant and legislator used to obtain bribes from said vendor.