US v. Townsend, No. 09-12797

Bribery Conviction Affirmed

In US v. Townsend, No. 09-12797, the court affirmed defendant's conviction for accepting bribes where 1) intangibles, such as freedom from jail and greater freedom while on pretrial release, were things of value under 18 U.S.C. section 666(a)(1)(B); 2) the market approach was a valid method for determining the value of an intangible obtained through bribery; and 3) there was enough evidence to support the jury's finding that defendant did help a suspect avoid apprehension.

As the court wrote:  "It has long been said that "the price of freedom is eternal vigilance," and maybe as a matter of political philosophy it is. When it comes to pretrial release from custody, however, some are willing to pay for freedom with cold hard cash, and the amount of freedom that one on supervised release has increases as the vigilance of his supervising officer decreases."

Related Resources

• Read the Eleventh Circuit's Decision in US v. Townsend, No. 09-12797