U.S. v. Pramaggiore

Defendants were convicted by a jury of a series of crimes involving transactions with the former Speaker of the Illinois of Representatives, including bribery, criminal conspiracy and falsifying books and records to conceal payments. After their conviction the district court vacated the bribery convictions based on changes to federal law. The Seventh Circuit then considered the conspiracy convictions and whether the evidence was sufficient to sustain those convictions. The appellate court concluded that it was not, finding that two of the four theories that the government pursued were legally invalid and, as a result, the conviction could have been based on improper reasons and the error was not harmless. (HAMILTON and KOLAR, concurring)