United States v. Lopez-Lukis

                   United States Court of Appeals,

                          Eleventh Circuit.

                            No. 95-3130.

         UNITED STATES of America, Plaintiff-Appellant,

                                 v.

 Vicki LOPEZ-LUKIS a.k.a. Vicki Lopez-Wolfe and Sylvester Lukis,
Defendants-Appellees.

                            Jan. 6, 1997.

Appeal from the United States District Court for the Middle
District of Florida. (No. 95-4-CR-FTM-21), Ralph W. Nimmons, Jr.,
Judge.

Before TJOFLAT, Circuit Judge, and RONEY and CAMPBELL*, Senior
Circuit Judges.

     TJOFLAT, Circuit Judge:

     Sections 1341 and 1346 of Title 18 of the United States Code,

the federal mail fraud statutes, make it unlawful to deprive the

electorate of a governmental office holder's "honest services."1

This interlocutory appeal presents the question of whether these

statutes make criminal a scheme in which a county commissioner, in

addition to selling her own votes to a lobbyist, takes steps to

ensure that a majority of commissioners vote for projects favored

by the lobbyist.     In this mail fraud prosecution, the district

     *
      Honorable Levin H. Campbell, Senior U.S. Circuit Judge for
the First Circuit, sitting by designation.
     1
      Section 1341 proscribes use of the mails as part of a
"scheme or artifice to defraud." 18 U.S.C. § 1341 (1994).
Section 1346 defines "scheme or artifice to defraud" to include
"a scheme or artifice to deprive another of the intangible right
of honest services." 18 U.S.C. § 1346 (1994). While these
statutes are clearly not limited to schemes involving
governmental officials, they frequently are used to combat
governmental corruption. See, e.g., United States v. Waymer, 55
F.3d 564 (11th Cir.1995), cert. denied, --- U.S. ----, 116 S.Ct.
1350, 134 L.Ed.2d 519 (1996).
court, ruling on a defense motion in limine, answered this question

in the negative and struck the portion of the indictment alleging

that the defendants' scheme to defraud included an attempt to

control the composition of the commission.          The court's order also

precluded the Government from introducing evidence that would

establish    this   objective.    The     Government   appealed;      we   now

reverse.

                                    I.

     Defendant      Vicki   Lopez-Lukis    is   a   former   member   of   the

five-person Board of County Commissioners for Lee County, Florida

("the Board").      She served on the Board from her election to office

in November 1990 until her resignation in January 1993.            Defendant

Sylvester Lukis is a lobbyist who represents clients before the

Board.     The defendants engaged in a romantic relationship during

Lopez-Lukis' term in office and were married subsequent to the

events giving rise to this case.2

                                    A.

     Lopez-Lukis and Lukis were indicted by a federal grand jury on

March 10, 1995. Count one of the indictment, which is supplemented

by a bill of particulars, charges both defendants with violating
                                                                      3
the federal mail fraud statutes, 18 U.S.C. §§ 1341, 1346.                  The

     2
      Presumably due to name changes related to different
marriages, Lopez-Lukis is also referred to in the record as Ms.
Lopez-Wolfe, Ms. Lopez-Wolfe-Lukis, and Ms. Lukis. For the sake
of clarity, we refer to her simply as "Lopez-Lukis."
     3
      Of the remaining ten counts, the defendants were indicted
together in eight counts of using a facility in interstate
commerce to commit bribery in violation of 18 U.S.C. § 1952
(1994), and each defendant was indicted separately for bribery in
violation of 18 U.S.C. § 666 (1994). Only the mail fraud count
is before us in this appeal.
indictment alleges that during Lopez-Lukis' term on the Board, the

defendants devised a scheme "to deprive the citizens of Lee County

and the State of Florida of their intangible right to [Lopez-

Lukis'] honest services ... in her official capacity as Lee County

Commissioner." Specifically, the defendants are charged with using

Lopez-Lukis' position for the benefit of Lukis' clients, two of

whom—Ogden    Projects,      Inc.,       and   Goldman-Sachs   and     Company—are

identified by name in the indictment.4

     The indictment alleges that Lukis paid Lopez-Lukis in order to

influence    her   actions    as     a   county   commissioner    and    that,   to

facilitate their scheme, the defendants concealed their "monetary

and intimate relationship" from the public.                 More important for

this appeal, however, paragraph fourteen of the mail fraud count

alleges that the defendants tried to prevent Susan Anthony, a

candidate    for   the   Board     who    opposed    the   interests    of   Lukis'

clients, from unseating Lopez-Lukis' fellow Board member John

Manning in the 1992 primary election.5              The alleged purpose of this

     4
      In its bill of particulars ordered by the district court,
the Government contends that the defendants helped Ogden
Projects, a contractor, retain its contract to construct a
multimillion-dollar waste-to-energy incinerator in Lee County and
ensure that the Board would allow the project to move forward.
Lukis and Lopez-Lukis were apparently successful in their efforts
on behalf of Ogden Projects: a final notice to proceed with
construction of the project was issued by the Board on October
21, 1992.

          The defendants also enjoyed apparent success in
     promoting the interests of Goldman-Sachs, a brokerage house.
     The Board voted to select Goldman-Sachs to perform
     underwriting work for public projects in Lee County,
     including an airport.
     5
      The indictment alleges that Anthony ran as "an
anti-incinerator candidate"; in other words, she opposed the
incinerator project being undertaken by Lukis' client, Ogden
endeavor was to control the composition of the Board to ensure that

it would continue to vote in favor of the interests of Lukis'

clients.6

       To     secure    Manning's       victory,    the   defendants         allegedly

threatened that, unless she withdrew from the race, they would

disseminate        to   several    media   organizations        a    videotape   that

depicted Anthony, who was campaigning as a family-values candidate,

engaging in an extramarital affair.                The Government's proffer to

the district court alleges that both defendants told Manning that

they       were   preparing   videotapes     that   would   "derail"         Anthony's

campaign.         When Anthony did not withdraw from the race, the

defendants        distributed     the   videotape    to   the       media.     Manning

subsequently defeated Anthony in the primary's run-off election. 7

We refer to this series of events collectively as the "videotape

incident."8


Projects. According to the proffer made by the Government at the
hearing on the defendants' motion in limine, Lukis and his
clients supported Manning in the election.
       6
      Paragraph 14 states that the defendants attempted to keep
Anthony off the Board to "corruptly affect the composition and
work of the Board of Lee County Commissioners ... to promote,
foster, further, facilitate and enlarge the scheme." Although
the indictment is inartfully drawn and the Government has had
considerable difficulty articulating the nature of this
allegation, we read ¶ 14 as charging that the defendants
attempted to manipulate the composition of the Board in order to
control a majority of votes.
       7
      In the primary's main election on September 1, 1992,
Anthony received the most votes, but because of a third
candidate, she did not command a majority. The next day the
local newspaper ran a story about the videotape. Manning soundly
defeated Anthony in the run-off on October 1, 1992.
       8
      The parties have offered different explanations of the
events surrounding the videotape incident, including how and why
the videotape was made and what motivated Lopez-Lukis to issue
                                     B.

     Early in the case, the defendants moved to strike paragraph

fourteen from the indictment.        As grounds for their motion, the

defendants argued that the allegations of paragraph fourteen were

irrelevant to the crime charged (i.e., mail fraud under sections

1341 and 1346), that their conduct described in that paragraph was

protected by the First Amendment, and that litigation of its

allegations would "needlessly complicate and lengthen the process

of trying this case."       The district court summarily denied their

motion on June 20, 1995.

     The defendants later moved in limine to exclude "any and all

evidence relating to any surveillance videotape of Susan Anthony"

on the same grounds as they presented in support of their earlier

motion   to    strike.    The   district   court   heard   this   motion   on

September 1, 1995.       Ruling from the bench on September 5, the day

before the trial was to commence, the court concluded that because

the videotape incident did not involve Lopez-Lukis' official duties

as county commissioner, it was not the sort of conduct proscribed

by sections 1341 and 1346.9      In granting the defendants' motion to

the threat. While these explanations may or may not be probative
at trial, depending on how the facts are developed, they are
irrelevant for purposes of this appeal. All that is important
for present purposes is that Lopez-Lukis threatened to
disseminate the tapes if Anthony did not abandon her candidacy,
that the defendants informed Manning of her threat, and that they
released the tapes after she refused to drop out of the race.
     9
      As the court stated:

                   Unlike other elements of the scheme or artifice
              which clearly allege methods and means by which
              services in her official capacity were affected or
              sought to be affected, such as the payment of money to
              influence her in her acts or decisions in her official
suppress all evidence related to the videotape incident, the court

vacated its earlier order denying the motion to strike and granted

that    motion   as   well,   striking   paragraph   fourteen   from   the

indictment.      The Government immediately announced that it would
                                                                10
appeal the court's ruling;      it took this interlocutory appeal the

            capacity, her participation or complicity in either
            secretly or openly attempting to persuade a candidate
            for a seat on the County Commission to withdraw by
            threatening to expose such person to disgrace cannot,
            by any reasonable construction of the subject mail
            fraud statute, be regarded as actions or conduct in her
            official capacity as a County Commissioner. Her duties
            and responsibilities as a County Commissioner simply do
            not include the determination as to who is elected to
            serve on the County Commission.
       10
      Interlocutory district court orders, such as the one
involved in this case, ordinarily are not reviewable until the
court has entered final judgment. See 28 U.S.C. § 1291 (1994).
We have jurisdiction over this interlocutory appeal, however,
under 18 U.S.C. § 3731, which provides that "[a]n appeal by the
United States shall lie to a court of appeals from a decision or
order of a district court suppressing or excluding evidence ...
in a criminal proceeding." 18 U.S.C. § 3731 (1994). While the
part of the district court's order striking ¶ 14 from the
indictment does not fall within this statutory exception,
"pendent jurisdiction and the doctrine of judicial economy permit
us to exercise jurisdiction over related claims when other claims
are properly reviewable." Hill v. Dekalb Reg'l Youth Detention
Ctr., 40 F.3d 1176, 1183 (11th Cir.1994).

            Although the Supreme Court rejected our use of pendent
       party appellate jurisdiction in Swint v. Chambers County
       Comm'n, --- U.S. ----, 115 S.Ct. 1203, 131 L.Ed.2d 60
       (1995), Swint does not bar jurisdiction in this case. That
       case dealt only with the use of pendent jurisdiction over a
       nonappealable issue involving parties different from those
       involved in the appealable issue. Swint was a civil rights
       case based on alleged misconduct by local police. The
       defendants in that case included three individual police
       officers and the local county commission. The district
       court had denied summary judgment motions by all defendants,
       and all defendants sought interlocutory appellate review.
       The individual officers' motions for summary judgment were
       based on qualified immunity; thus, we had immediate
       appellate jurisdiction over the denial of these motions
       under the narrow exception to the final judgment rule laid
       out in Mitchell v. Forsyth, 472 U.S. 511, 105 S.Ct. 2806, 86
next day, the day the trial was to begin.             The district court

stayed further proceedings in the case pending the outcome of this

appeal.

     We hold that the district court misconstrued section 1346 and

improperly    narrowed   the   scope   of   the   scheme   alleged   by   the

Government.    We therefore reverse its order striking paragraph

fourteen from the indictment and excluding all evidence relating to

the videotape incident.

     L.Ed.2d 411 (1985). Swint v. City of Wadley, 5 F.3d 1435,
     1448-49 (11th Cir.1993), modified, 11 F.3d 1030 (11th
     Cir.1994), vacated in part sub nom. Swint v. Chambers
     County Comm'n, --- U.S. ----, 115 S.Ct. 1203, 131 L.Ed.2d 60
     (1995). We invoked pendent jurisdiction to review the order
     denying the county commission's summary judgment motion,
     even though it was an interlocutory order over which we
     would normally not have immediate appellate jurisdiction
     because it did not raise the defense of qualified immunity.
     Swint, 5 F.3d at 1449-50. It was this use of pendent
     jurisdiction that the Supreme Court rejected. Swint, ---
     U.S. at ---- - ----, 115 S.Ct. at 1208-12.

          The Court explicitly refrained, however, from
     "definitively or preemptively" rejecting the use of pendent
     appellate jurisdiction over related claims. It suggested
     that pendent appellate jurisdiction may be appropriate when
     a nonappealable decision is "inextricably intertwined" with
     an appealable decision or when "review of the former
     decision [is] necessary to ensure meaningful review of the
     latter." Id. at ----, 115 S.Ct. at 1212; see also Johnson
     v. Clifton, 74 F.3d 1087, 1091 (11th Cir.1996), petition for
     cert. filed, --- U.S. ----, 117 S.Ct. 51, 136 L.Ed.2d 15
     (1996) (No. 95-1743).

          Because the district court's order striking the
     indictment is so closely related to its exclusion of the
     Government's evidence, we are confident that our application
     of pendent jurisdiction is proper in this case. Review of
     the order striking ¶ 14 from the indictment satisfies both
     the "inextricably intertwined" and "necessary to ensure
     meaningful review" tests. Both orders resulted from the
     same determination—i.e., that the videotape incident cannot
     be used to support a charge of mail fraud under §§ 1341 and
     1346. Furthermore, review of the evidentiary ruling
     necessarily implicates review of the order striking ¶ 14
     from the indictment.
                                  II.

          The district court apparently based its decision that the

videotape incident could not be used to prove mail fraud not on the

question of factual relevance, but on the question of whether this
                                                         11
conduct "fit" within the parameters of section 1346.          We review

this question of statutory interpretation de novo.       See National

Coal Ass'n v. Chater, 81 F.3d 1077, 1081 (11th Cir.1996).

     A proper understanding of the scheme alleged is essential to

the resolution of this appeal.          The heart of count one is an

allegation of a broad bribery scheme:       Lukis paid Lopez-Lukis for

political favors.     The present controversy centers on exactly what

Lukis' money bought.       The indictment alleges that Lukis bribed

Lopez-Lukis because he thought that she would give him two things:

     11
          The district judge stated:

             While [the videotape incident] is, indeed,
             reprehensible and illegal, it is simply outside the
             framework of the subject mail fraud charge under
             Section 1346.

                  The Court has simply not been able to fit this
             transaction into the mail fraud scheme which is the
             subject of Count 1. It stands out as a peculiarly
             inappropriate part of this mail fraud count.

          The district court also noted that the mailing upon
     which the mail fraud charge is based was sent almost a year
     before the videotape incident and shared "no connection"
     with the videotape incident. The degree to which the
     district court considered this to be determinative is
     unclear, but to the extent that it relied on this
     observation as grounds for excluding the evidence, it was in
     error. There is no requirement that every piece of evidence
     of the scheme to defraud somehow relate to the mailing. The
     only requirement is that the mailing be related to some
     "step in the plot." United States v. Waymer, 55 F.3d 564,
     569 (11th Cir.1995) (quoting Schmuck v. United States, 489
     U.S. 705, 711, 109 S.Ct. 1443, 1448, 103 L.Ed.2d 734
     (1989)), cert. denied, --- U.S. ----, 116 S.Ct. 1350, 134
     L.Ed.2d 519 (1996).
(1) her vote on key matters and (2) control of the Board—that is,

her influence to deliver a majority of the Board's votes on those

matters.    The central question in this appeal is whether sections

1341 and 1346 reach such a bribery scheme.

     We believe the answer to this question should be self-evident:

if it is illegal for a public official to sell her own vote, it

also must be illegal for her to sell her vote and her influence

over other's votes as well.                After all, because the Board consists

of five members and presumably acts by majority vote, it would do

Lukis little good if all that his money purchased was Lopez-Lukis'

single vote.

     In this section, we first explain why a scheme by a legislator

to deliver control of a majority of legislative votes for a price

constitutes a scheme to defraud, as defined by sections 1341 and

1346.      We       then   address     the    district   court's     reasoning     and

demonstrate         why    it   is    erroneous.      Finally,     we    examine   the

allegations against the defendants and show why they manifest an

attempt to deliver control of the Board.

                                              A.

     A   brief        review     of    the    mail   fraud    statutes    and   their

interpretation by the courts is helpful to understanding why they

proscribe       a    scheme     for    a    legislator   to   sell   control    of   a

legislative body when that scheme includes use of the mails.                         To

establish a violation of sections 1341 and 1346, the Government

must prove that the defendants "(1) intentionally participated in

a scheme or artifice to defraud and (2) used the United States

mails to carry out that scheme or artifice."                   Waymer, 55 F.3d at
568 (citing United States v. Hooshmand, 931 F.2d 725, 731 (11th

Cir.1991)).

     At common law, the prohibition of fraud generally was regarded

as protecting property rights only.    See McNally v. United States,

483 U.S. 350, 358 n. 8, 107 S.Ct. 2875, 2881 n. 8, 97 L.Ed.2d 292

(1987).   As early as the 1940s, however, federal prosecutors

seeking to combat government corruption began using section 1341 to

prosecute schemes to defraud the public of the honest and faithful

services of government officials.      See, e.g., Shushan v. United

States, 117 F.2d 110 (5th Cir.), cert. denied, 313 U.S. 574, 61

S.Ct. 1085, 85 L.Ed. 1531 (1941).      In the 1987 McNally case, the

Supreme Court rejected this practice by holding that section 1341

was "limited in scope to the protection of property rights" and

therefore did not prohibit schemes to defraud the citizens of their

intangible right to honest and impartial government.     McNally, 483

U.S. at 360, 107 S.Ct. at 2882.

     Section    1346   was   enacted    in   1988   to   revive   the

"honest-services" theory of mail fraud.      We have recognized that

Congress passed this provision to overrule McNally and reinstate

prior law.     See Waymer, 55 F.3d at 568 n. 3. Consequently, we

consider pre-McNally cases as persuasive authority in evaluating
                                                                   12
the scope of honest-services fraud.    Both the former Fifth Circuit
before McNally and this circuit after McNally consistently have

held that schemes by government officials to deprive the public of


     12
      In Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th
Cir.1981) (en banc), this court adopted as binding precedent all
decisions of the former Fifth Circuit handed down prior to
October 1, 1981.
its right to their honest services, when a mailing is involved,

constitute mail fraud. See, e.g., United States v. Castro, 89 F.3d

1443 (11th Cir.1996);          Waymer, 55 F.3d 564;            Steiner v. United

States, 134 F.2d 931 (5th Cir.), cert. denied, 319 U.S. 774, 63

S.Ct. 1439, 87 L.Ed. 1721 (1943);              Shushan, 117 F.2d 110.

      The crux of this theory is that when a political official

uses his office for personal gain, he deprives his constituents of

their right to have him perform his official duties in their best

interest.    Elected officials generally owe a fiduciary duty to the

electorate.        See Shushan, 117 F.2d at 115 (noting that "[n]o

trustee has more sacred duties than a public official").                        When a

government       officer   decides       how   to    proceed    in   an    official

endeavor—as when a legislator decides how to vote on an issue—his

constituents have a right to have their best interests form the

basis of that decision. If the official instead secretly makes his

decision based on his own personal interests—as when an official

accepts a bribe or personally benefits from an undisclosed conflict

of interest—the official has defrauded the public of his honest

services.        See United States v. Sawyer, 85 F.3d 713, 724 (1st

Cir.1996) ("The cases in which a deprivation of an official's

honest services is found typically involve either bribery of the

official    or    her   failure   to     disclose     a   conflict   of   interest,

resulting in personal gain.").

      The appellees concede that a county commissioner commits

honest-services fraud when she sells her vote.                  It is no less a

violation     of    sections      1341     and      1346,   however,      for     that

commissioner, in addition to selling her vote, to take steps to
ensure that a majority of commissioners vote with her.                  See

generally Shushan, 117 F.2d 110 (affirming mail fraud convictions

for broad scheme involving bribery of two members of board of

commissioners who attempted to influence actions of entire board).

In both scenarios, the commissioner deprives her constituents of

their right to her honest services by deciding how to vote based on

her   own   interests.    The     second   scenario   simply   makes   this

deprivation    more   concrete.       In   addition   to   depriving    her

constituents of their right to her honest services, she seeks to

ensure that the actions the Board takes are in her own best

interests instead of the best interests of the public.13

      One commissioner's vote, without more, does not guarantee that

a particular legislative proposal favored by the briber will

succeed.    Any such measure generally requires a majority vote from

the commission.    While we do not mean to suggest that the bribery

of a single official for a vote cannot sustain a conviction for

mail fraud,14 that an official took steps to ensure that her

      13
      This analysis does not suggest that, under such a
scenario, the other commissioners are necessarily depriving their
constituents of the right to honest services. It is entirely
possible that they will decide that proposals that she supports
are in fact in the best interest of the electorate and vote
accordingly. In this case, only the bribed commissioner would be
depriving her constituents of their right to honest services.

           That the result of the bribed commissioner's vote
      actually benefits the electorate would not change the
      fraudulent nature of her conduct. Sections 1341 and 1346 do
      not address the wisdom or results of a legislative decision;
      rather they concern the manner in which officials make their
      decisions.
      14
      To the contrary, as we stated long ago, "[t]he fact that
the official who is bribed is only one of several and could not
award the contract by himself does not change the character of
the [fraudulent] scheme." Shushan, 117 F.2d at 115.
fraudulent scheme would yield results makes the case against her

more compelling.        Such actions increase the likelihood that the

scheme   to       defraud   the    electorate        of   their    right   to    the

commissioner's honest services will bear fruit.                    Surely section

1346 was intended to prohibit just this sort of conduct, and today

we hold that it does.

                                         B.

     The district court construed section 1346 to proscribe conduct

aimed at obtaining an individual legislator's vote, but no more.

By excluding evidence necessary to prove the existence of a larger

scheme, it narrowed the scheme's scope from an attempt to obtain

control of the Board to an attempt to procure a single vote.                     This

narrow interpretation of the mail fraud statutes was erroneous.

     The court ruled that the videotape incident was outside the

scope of section 1346 because it did not involve Lopez-Lukis'

official duties.       As the court noted, "[Lopez-Lukis'] duties and

responsibilities as a County Commissioner simply [did] not include

the determination as to who is elected to serve on the County

Commission."         Even   if    we   assume   that      honest-services       fraud

involving     a    public   official     can    be    predicated    only   on    the




          Several scenarios may be imagined in which a potential
     briber might only need a single vote. For example, the
     bribed official might chair a committee and have power to
     decide which issues come before the body for a vote and the
     manner in which they are addressed. Similarly, if passage
     of particular legislation only required a single additional
     vote—that is, a number of officials already supported the
     legislation for their own reasons—buying that extra vote
     alone would be desirable.
performance of services in an official capacity,15 the court's

ruling     misconceives    the   nature   of   the   scheme   alleged   in   the

indictment.

      The object of the alleged scheme was not to keep Anthony off

the Board or otherwise determine who would serve on the Board.

Rather, the goal was for Lopez-Lukis to receive personal benefits

in exchange for her efforts to secure Board action that favored the

interests of Lukis' clients.         The videotape incident is relevant

for   at   least   two    reasons.    First,    because   the   incident     was

allegedly designed to keep Manning, who would likely vote for

projects favored by Lukis' clients, on the Board, it tends to show

that Lopez-Lukis had an agenda to serve the interests of Lukis'

clients instead of the interests of her constituents.

      Second, the videotape incident also demonstrates that the

scheme embraced more than just the compromising of one vote on the

Board.     The scheme involved efforts to influence decisions of the

entire Board.      Lopez-Lukis' single vote, without more, could not

carry out the objectives of the defendants' scheme to procure Board

action favorable to Lukis' clients. To pass, any measure favorable

to Lukis' clients required a majority of the Board's votes—that is,

the votes of Lopez-Lukis and at least two others.               To the extent

she exercised influence over the composition and voting of the

Board, Lopez-Lukis made the deprivation of her constituents' right

to her honest services more complete and profitable.                    In this

regard, the videotape incident may be viewed merely as a means to


      15
      Because it is not dispositive in this case, we decline to
rule on this issue.
an end.   Thus, the Government does not seek to predicate mail fraud

liability      on   the   videotape    incident   itself;      it    is   merely

attempting to use the incident as circumstantial proof of a broad

scheme to defraud.

      While we need not and do not decide the issue, it may be true

that the videotape incident, standing alone, could not support

criminal liability under section 1346 because it did not directly

involve conduct in Lopez-Lukis' official capacity.              If true, this

proposition would not mean, however, that the Government cannot
introduce such evidence to demonstrate a broad scheme to control

and obtain favorable votes from the Board.           Because the videotape

incident tends to show both that Lopez-Lukis intended to benefit

Lukis' clients instead of the public and that the scheme was more

likely    to   succeed,    it   is   clearly   relevant   to   the   charge   of

honest-services fraud and properly was charged in the indictment as

part of her overall scheme.16

     16
      For this reason, two other arguments that the appellees
stress in their brief are misguided. In addition to agreeing
with the district court's official-duty analysis, the appellees
offer two other, alternative arguments that would justify
affirming its order even though the district court did not
address them. They first point to the line of cases beginning
with Fasulo v. United States, 272 U.S. 620, 47 S.Ct. 200, 71
L.Ed. 443 (1926), which hold that extortion cannot be the basis
for a mail fraud conviction. The appellees argue that the
videotape incident, as alleged, constitutes extortion and thus is
not covered by § 1346. Second, they argue that their actions
constitute political speech and thus deserve protection under the
First Amendment.

          Again, we need not decide whether the videotape
     incident alone can support a mail fraud conviction. The
     government is seeking to punish the defendants not because
     they tried to keep a candidate from being elected to the
     Board, but because they used Lopez-Lukis' office for
     personal benefit. Evidence of the videotape incident tends
     to show both that Lopez-Lukis intended to ensure that the
     Any hard and fast rule that the government cannot use a public

official's conduct that is not in an official capacity as evidence

of a scheme to defraud the public of an official's honest services

would impermissibly narrow the scope of section 1346 and "would

belie a clear congressional intent to construe the mail fraud

statute broadly," Castro, 89 F.3d at 1456.   Therefore, we decline

to read such a rule into the statute.

                                C.

     The appellees argue in their brief that regardless of whether
the district court erred in its interpretation of section 1346, we

should affirm its ruling because the Government failed to proffer

any evidence that keeping Anthony off the Board would further the

interests of Lukis' clients.     While any implication that the

videotape incident was part of a scheme to control the Board might




     Board would vote for the interests of Lukis' clients and
     that their scheme was likely to succeed.

          Even if the videotape incident could not serve as a
     proper independent basis for imposing criminal
     liability—either because of the rule set down in Fasulo or
     because of First Amendment concerns—the Government may use
     it as evidence that the defendants engaged in a broad scheme
     to defraud the public. Cf. Huff v. United States, 301 F.2d
     760, 765 (5th Cir.) ("[F]raud and extortion are not mutually
     exclusive. The mere fact that extortion may constitute one
     aspect of the transaction does not insulate the fraudulent
     ... plan from prosecution as a scheme to defraud.")
     (interpreting wire fraud statute, 18 U.S.C. § 1343), cert.
     denied, 371 U.S. 922, 83 S.Ct. 289, 9 L.Ed.2d 230 (1962);
     Waymer, 55 F.3d at 569 ("Assuming arguendo that certain
     marginal applications of section 1346 would impermissibly
     intrude on First Amendment rights, we hold that such
     potential problems with section 1346 are insubstantial when
     judged in relation to the statute's plainly legitimate
     sweep.").
hinge     to   some     degree   on   such      evidence,17   the     appellees

characterization of the Government's evidence is not supported by

the record. The Government has offered to prove several facts that

could persuade a rational factfinder that Lopez-Lukis could control

a majority of Board votes more easily with Manning, instead of

Anthony, on the Board.

     For example, the Government has proffered that Lopez-Lukis

told Manning that she was going to "derail" Anthony's campaign

against    him.       This   allegation,   if   proven,   would      support   an

inference that Manning owed a political debt to Lopez-Lukis and

likely would vote with her on key issues.           Thus, Lopez-Lukis could

better obtain votes favorable to Lukis' present or future clients

with Manning on the Board.

     Moreover, the record is replete with evidence that, without

Anthony, the Board would be more likely to vote in favor of the

interests of at least two of Lukis' current clients—Ogden Projects

and Goldman-Sachs. First, the indictment specifically alleges that

Anthony opposed Ogden Projects' incinerator project.                Had she been
                                                               18
elected, she posed a serious threat to the project.                  Second, in

     17
      Of course, even without this kind of evidence a factfinder
might infer that the defendants were trying to gain control of
the Board to benefit Lukis' future clients. As a lobbyist, Lukis
could certainly use control of the Board as a valuable asset in
soliciting additional clients.
     18
      See supra note 4 (describing this project in greater
detail). The appellees contend that because the final notice to
proceed on the project had been issued before Anthony could have
taken office, Anthony could have no impact on the project. This
contention is flawed. Had she been elected, she could have voted
to terminate the project or cause problems throughout
construction. The fact that she was running on an
"anti-incinerator" platform certainly suggests she would have
done everything in her power to halt or delay the project.
its proffer the Government offered to prove that Lukis helped raise

funds for Manning's campaign and that officials from Goldman-Sachs

and Ogden Projects contributed to Manning's campaign fund.    This

evidence suggests that Manning would further the interests of

Lukis' clients if re-elected, or at least that Lukis' clients

assumed he would.   In short, keeping Anthony off the Board formed

an important step in effectuating the defendants' alleged scheme to

sell control of the Board.19

                               III.

     For the foregoing reasons, we REVERSE the district court's

grant of the defendants' in limine motion seeking the exclusion of

the evidence relating to the videotape incident and its order

striking paragraph fourteen from the indictment.    We REMAND this

case to the district court for further proceedings consistent with

this opinion.

     SO ORDERED.




     19
      The appellees argue in their brief that the risk of
prejudice and undue delay substantially outweighs any relevance
the videotape incident has to the mail fraud charge. Thus, they
contend that any evidence concerning the videotape incident
should be excluded under Federal Rule of Evidence 403. Because
the trial court's ruling appears to be based on its
interpretation of § 1346 and not on considerations of relevance
and prejudice, we refrain from ruling on this issue. However, as
our analysis of the videotape incident suggests, the value of
this evidence may be sufficiently probative to render exclusion
under Rule 403 an abuse of discretion.