U.S. v. Snyder

Record contained sufficient evidence to support jury’s guilty verdicts on charges of bribery, arising out of defendant-former mayor’s receipt of $13,000 in connection with city’s purchase of garbage trucks, as well as concealment of assets from IRS. While defendant argued that he was entitled to dismissal of indictment or disqualification of prosecution team because police violated his Fourth and Sixth Amendment rights when they seized pursuant to search warrant three emails that contained privileged communications between himself and his legal counsel, Dist Ct. could properly reject defendant’s Fourth Amendment claim, where defendant’s requested remedies are not proper remedies for any Fourth Amendment violation, which is limited to suppression of evidence. Also, there was no Sixth Amendment violation, where defendant’s Sixth Amendment rights had not attached at time of instant seizure, since defendant had not been indicted on instant charges at time of seizure. Fact that defendant had retained counsel, who was negotiating with government regarding potential criminal charges prior to seizure, did not require different result. Moreover, Ct. of Appeals rejected defendant’s claim that government’s use of allegedly defective filtering process to insulate any privileged material from prosecution deprived him of his Sixth Amendment rights. Too, record supported guilty verdict on concealment of assets from IRS charge, where record showed that defendant owed both personal and payroll taxes and devised scheme to divert assets from bank accounts that IRS had previously imposed levies. Fact that defendant had eventually paid his personal taxes through installment plan did not require different result.