United States v. Kehoe

675 F. Supp. 1109, 1987 U.S. Dist. LEXIS 12376, 1987 WL 25543
CourtDistrict Court, N.D. Illinois
DecidedDecember 18, 1987
DocketNo. 85 CR 770, 85 CR 773, 85 CR 775 and 85 CR 776
StatusPublished

This text of 675 F. Supp. 1109 (United States v. Kehoe) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Kehoe, 675 F. Supp. 1109, 1987 U.S. Dist. LEXIS 12376, 1987 WL 25543 (N.D. Ill. 1987).

Opinion

[1110]*1110ORDER

BUA, District Judge.

This case comes before the court on remand from the Seventh Circuit, 817 F.2d 440. The Court of Appeals has asked this court to reconsider defendants’ mail fraud convictions in light of McNally v. United States, — U.S. -, 107 S.Ct. 2875, 97 L.Ed.2d 292 (1987). Based on McNally, defendants have moved to vacate their convictions and dismiss the charges against them. For the reasons stated herein, this court denies defendants' motion and upholds their convictions.

FACTS

The indictment in this case arises from a scheme involving Manning Savings and Loan Association (Manning), a Chicago-based financial institution that is now defunct. As a recipient of deposit insurance from the Federal Savings and Loan Insurance Corporation (FSLIC), Manning was required to maintain a certain minimum net worth pursuant to Federal Home Loan Bank Board (FHLBB) regulations. See 12 C.F.R. 563.13 (1987). On November 12, 1981, the FSLIC and the FHLBB found that Manning had failed to meet its net worth requirements. In a recommended order dated July 14, 1982, an administrative law judge (AU) concurred in the finding that Manning’s net worth was inadequate. The AU declared that unless Manning satisfied its net worth requirements within the statutorily mandated 20-day period, the FHLBB would immediately order Manning to merge or consolidate with another institution.

Harold Ticktin, Manning’s president, sought to avoid a compelled merger. To that end, Ticktin devised a complex scheme to deceive the federal banking bureaucracy. As part of this scheme, Manning approved loan applications for the purchase of nearly 200 condominiums without requiring the loan applicants to make any down payments. Manning then made separate loans to other individuals, who kicked back part of the loan proceeds. Certain officers of Manning applied these kickbacks to the condominium loans, producing the false impression that down payments were being made. This scheme fostered the illusion that Manning’s net worth had risen to a level that complied with federal regulations.

The three defendants who filed the motion now under consideration all participated in Manning’s fraudulent loan scheme. As an employee of Elliott Financial Services, Kevin Kehoe helped arrange the sham loan transactions by recruiting applicants for the condominium loans. These applicants used the loan proceeds to purchase 71 condominiums in Orland Park, Illinois and 123 condominiums in Forest Park, Illinois. For each condominium, Kehoe received a $15,000 commission from Manning. In a transaction completely unrelated to the condominiums, Robert Lang and Robert Bailey received loans from Manning with the understanding that they were to kick back part of the loan proceeds. These kickbacks created the appearance that Manning was collecting down payments on the condominium loans.

Federal officials eventually discovered the Manning scheme. On December 4, 1985, a grand jury indicted seven people in connection with the scheme. The indictment charged Kehoe, Lang, and Bailey with a single offense: violation of the mail fraud statute, 18 U.S.C. § 1341 (1982). According to the indictment, these defendants deprived the FSLIC, the FHLBB, and Manning’s depositors and shareholders of “their right to have the affairs of Manning ... conducted honestly, fairly, and free from craft, trickery, deceit, corruption, dishonesty and fraud.”

A jury convicted Kehoe, Lang, and Bailey of mail fraud. While their appeals were pending in the Seventh Circuit, the U.S. Supreme Court ruled in McNally v. United States, supra, that deprivations of intangible rights fall outside the scope of the mail fraud statute. The McNally decision triggered a remand to this court for reconsideration of the three defendants’ convictions. Arguing that this court cannot sustain their convictions after McNally, Ke-hoe, Lang, and Bailey have moved to va[1111]*1111cate the judgments of guilty entered against them.

DISCUSSION

In McNally, the Supreme Court held that Congress did not intend for the mail fraud statute to protect “the intangible right of the citizenry to good government.” 107 S.Ct. at 2879. By restricting the scope of the statute to the protection of property rights, the McNally decision has sparked a re-examination of all mail fraud convictions stemming from alleged infringements of intangible rights. In the wake of McNally, some courts have overturned convictions founded on intangible rights theories, concluding that the underlying indictments failed to state an offense under the mail fraud statute. See, e.g., United States v. Gimbel, 830 F.2d 621 (7th Cir.1987); United States v. Mandel, 672 F.Supp. 864 (D.Md.1987).

Nonetheless, McNally does not require automatic reversal of a mail fraud conviction any time an indictment invokes some intangible rights doctrine. A number of courts have rejected McNally challenges to mail fraud convictions, even though the indictments at issue relied in part on an intangible rights theory. See, e.g., United States v. Runnels, 833 F.2d 1183 (6th Cir.1987); United States v. Wellman, 830 F.2d 1453 (7th Cir.1987); United States v. Keane, No. 74 CR 359 (N.D.Ill.Dec. 7,1987) [Available on WESTLAW, 1987 WL 27437]. United States v. Gill, 673 F.Supp. 275 (N.D.Ill.1987) (originally filed in the Western Division of the Northern District of Illinois). These courts relied on two factors in rebuffing defendants’ McNally claims. First, in addition to advancing an intangible rights theory, each of the challenged indictments contained allegations of property deprivation — an offense that remains punishable under the mail fraud statute, even after McNally. Second, the inextricable connection in these cases between the property-based allegations and the intangible rights theories insured that the defendants received a full and fair trial for an offense encompassed by the mail fraud statute.

These same factors characterize the case at bar, the latest of McNally’s offspring. Obviously, the convictions of Kehoe, Lang, and Bailey cannot stand unless the case against these defendants “is plainly within the [mail fraud] statute.” Fasulo v. United States, 272 U.S. 620, 629, 47 S.Ct. 200, 202, 71 L.Ed. 443 (1926). The three defendants contend that they were convicted of an offense that falls outside the scope of the statute: an alleged violation of the intangible right to honest business administration. Upon closer scrutiny, however, this case essentially involves the unauthorized taking of property — a cognizable offense under the mail fraud statute.

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Related

Fasulo v. United States
272 U.S. 620 (Supreme Court, 1926)
McNally v. United States
483 U.S. 350 (Supreme Court, 1987)
United States v. Stanley P. Gimbel
830 F.2d 621 (Seventh Circuit, 1987)
United States v. Glenn Wellman
830 F.2d 1453 (Seventh Circuit, 1987)
United States v. Gill
673 F. Supp. 275 (N.D. Illinois, 1987)
United States v. Mandel
672 F. Supp. 864 (D. Maryland, 1987)

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Bluebook (online)
675 F. Supp. 1109, 1987 U.S. Dist. LEXIS 12376, 1987 WL 25543, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-kehoe-ilnd-1987.