In U.S. v Townsend, No. 09-12 (Jan. 13, 2011), the Court affirmed convictions of a Miami-Dade County corrections officer, convicted for giving a defendant on pretrial release greater freedoms in exchange for bribes.
The Court found that giving greater freedom to a defendant on pretrial release qualified as a “thing of value of $5,000 or more” for purposes of the bribery statute, 18 U.S.C. § 666. The Court held that a thing of value can be “intangible.” Further, because the monetary value of the bribes paid to Townsend totaled $5,280, the value of this intangible (the defendant’s greater freedom) exceeded $5,000.
The Court rejected sufficiency of the evidence challenges to Townsend’ remaining convictions for obstruction of justice, finding that phone calls Townsend made to the defendant to warn him of a pending search of his home, and other evidence, proved these violations.
