United States v. Blake

684 F. Supp. 441, 1988 U.S. Dist. LEXIS 4249, 1988 WL 47042
CourtDistrict Court, S.D. Mississippi
DecidedApril 15, 1988
DocketCrim. A. No. J87-00099(L)
StatusPublished

This text of 684 F. Supp. 441 (United States v. Blake) is published on Counsel Stack Legal Research, covering District Court, S.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Blake, 684 F. Supp. 441, 1988 U.S. Dist. LEXIS 4249, 1988 WL 47042 (S.D. Miss. 1988).

Opinion

MEMORANDUM OPINION

TOM S. LEE, District Judge.

This cause is before the court on the motion of defendant Presley L. Blake, Jr. to dismiss portions of the indictment against him in this cause. The government filed timely response to the motion and upon consideration of the issues raised by defendant, the court is of the opinion that his motion is well taken and should be granted.

The indictment, which consists of six counts, charges defendant with various violations based on allegations that the de[442]*442fendant paid fees to officers, directors and employees of the Mississippi Bank in order to procure loans from the bank. In count one of the indictment, the defendant is charged with aiding, abetting, counselling and conspiring with employees of the Mississippi Bank to violate 18 U.S.C. § 1006 (1976) which prohibits officers, agents or employees of certain financial institutions from participating, sharing or receiving, directly or indirectly, any money, profit, property or benefits through any transaction, loan, commission or contract of the financial institution. In his motion as it pertains to count one, defendant argues that the Mississippi Bank is not a financial institution within the coverage of Section 1006 and that the statute is therefore inapplicable. The government has conceded the correctness of defendant’s position and accordingly, the court is of the opinion and so finds that that part of count one of the indictment charging conspiracy to violate 18 U.S.C. § 1006 should be dismissed.

Counts two through six charge defendant with violations of the Travel Act, 18 U.S.C. § 1952(a)(3) (Supp.1987). The substance of the allegations contained in those counts is that defendant made certain payments, by check, to officers, directors and employees of the Mississippi Bank in return for loans from the bank and in doing so used a facility in interstate commerce with the intent to promote, manage or carry on a violation of 18 U.S.C. § 215 (Supp.1987), and thereafter performed acts to promote, manage, carry on and facilitate a violation of 18 U.S.C. § 215. The Travel Act, 18 U.S.C. § 1952(a)(3), provides that

(a) whoever travels in interstate or foreign commerce or uses any facility in interstate or foreign commerce, including the mail, with intent to
(3) promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on, of any unlawful activity, and thereafter performs or attempts to perform any of the acts specified in subparagraphs (1), (2), and (3), shall be fined not more than $10,000 or imprisoned for not more than five years or both.

For there to have been a violation of the Travel Act, it is necessary that the defendant have traveled in interstate commerce or used “any facility in interstate or foreign commerce” to carry on the charged unlawful activity. That is, under the Travel Act, there is a requirement that there be some nexus between the use of the facility in interstate commerce and the act charged, here bribery. The question for decision before the court, then, is whether the clearing of checks through the federal reserve system is a sufficient interstate nexus to support jurisdiction under the Travel Act. Under the particular facts presented, the court is of the opinion that it is not.

The sole basis upon which Travel Act jurisdiction is predicated is the clearing of five checks described in counts two through six of the indictment through the Federal Reserve Bank in Memphis, Tennessee and New Orleans, Louisiana. Each of the checks was drawn on the Bank of Greenwood, a branch of First National Bank in Jackson, Mississippi, during the years 1982 and 1983. Four of the cheeks were processed for clearing through the Federal Reserve Bank in Memphis; one was processed through the Federal Reserve Bank in New Orleans. That is, the checks were allegedly given by one Mississippi resident to other Mississippi residents and were each drawn on a Mississippi bank. The only connection with interstate commerce was the fortuitous clearing of the checks through federal reserve banks outside the State of Mississippi.

In Rewis v. United States, 401 U.S. 808, 91 S.Ct. 1056, 28 L.Ed.2d 493 (1971), the Supreme Court interpreted the Travel Act as inapplicable where the interstate activity was purely incidental to the illegal operation. Rewis, 401 U.S. at 813, 91 S.Ct. at 1060. Specifically, the Court held that Travel Act jurisdiction was lacking where the only interstate element was the fact that out-of-state customers patronized the defendant’s gambling establishment. The Court observed that

an expansive Travel Act would alter sensitive federal-state relationships, could overextend limited federal police re[443]*443sources, and might well produce situations in which the geographic origin of customers, a matter of happenstance, would transform relatively minor state offenses into federal felonies.

Id. at 812, 91 S.Ct. at 1059. Accepting, at least for purposes of argument, that the federal reserve system is an interstate facility, and the clearing of checks through that system is a use, even if inadvertent, of such facility, the court is nevertheless of the opinion that the interstate nexus in the case at bar is too tenuous to support the exercise of jurisdiction.

This case closely resembles United States v. Isaacs, 493 F.2d 1124 (7th Cir.), cert. denied, 417 U.S. 976, 94 S.Ct. 3184, 41 L.Ed.2d 1146 (1974), in which the defendant was indicted for his involvement in a scheme to bribe, among others, the governor of Illinois. In Isaacs, as in the present case, federal jurisdiction was founded upon the use of the federal reserve system; three of the checks had been drawn on a local bank and had been deposited by their recipients in local banks, but the checks had cleared through a federal reserve bank outside the state. The court there concluded that “the use of interstate facilities here was so minimal, incidental, and fortuitous, and so peripheral to the activities of [defendants] and other participants in this bribery scheme, that it was error to submit [the Travel Act counts] to the jury. Isaacs, 493 F.2d at 1146. Similarly, in United States v. Altobella, 442 F.2d 310 (7th Cir.1971), jurisdiction was based upon the defendants’ having accepted, in an extortion scheme, a check from their victim written on an out-of-state bank, and on their having cashed that check. There, the court held that while the defendants had committed a crime, it was not a federal crime since the use of interstate facilities, i.e., the federal reserve system, “was purely incidental to appellants’ sordid scheme.” Altobella,

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Related

Rewis v. United States
401 U.S. 808 (Supreme Court, 1971)
Perrin v. United States
444 U.S. 37 (Supreme Court, 1979)
United States v. Frank Altobella and James Moxley
442 F.2d 310 (Seventh Circuit, 1971)
United States v. Talmadge G. Rauhoff
525 F.2d 1170 (Seventh Circuit, 1975)
United States v. Silas Jones
642 F.2d 909 (Fifth Circuit, 1981)
United States v. John Garrett and L.G. Moore
716 F.2d 257 (Fifth Circuit, 1983)
Cox v. Chesapeake & Ohio Railroad
417 U.S. 977 (Supreme Court, 1974)

Cite This Page — Counsel Stack

Bluebook (online)
684 F. Supp. 441, 1988 U.S. Dist. LEXIS 4249, 1988 WL 47042, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-blake-mssd-1988.