Friday, December 6, 2013

Tanner v. United States case brief

Tanner v. United States case brief summary
483 U.S. 107 (1987)

Defendants were convicted of various conspiracy and fraud charges under 18 U.S.C.S. §§ 371and 1341 arising out of their illegal construction practices on a project for a utility company that was financed by a loan guaranteed by the Rural Electrification Administration (REA). The United States Court of Appeals for the Eleventh Circuit affirmed the convictions, and the Court granted certiorari.

Defendants argued that the district court erred in refusing to admit juror testimony at a post-verdict hearing on juror intoxication during their trial and that the conspiracy indictment failed to charge a crime against the United States. Defendants were convicted of conspiracy and fraud charges under 18 U.S.C.S. §§ 371 and 1341.

  • The court held that the refusal to admit juror testimony was supported by Fed. R. Evid. 606(b) because it allowed a post-verdict inquiry only in cases of substantial, if not wholly conclusive, evidence of incompetency. 
  • The protection of jury deliberations from intrusive inquiry outweighed defendants' rights to inquire into the deliberations, especially in light of the insufficiency of non-juror evidence. 
  • As to defendants' concerns regarding the conspiracy count, the Court held that a conspiracy to defraud the United States could be effected by the use of third parties. 
  • Because 18 U.S.C.S. §371 covered only conspiracies to defraud the United States or any agency thereof, however, the action was remanded for a determination as to whether the evidence showed that defendants' conspiracy to defraud the utility company involved misrepresentations to the REA.
The Court affirmed the portion of the judgment that denied defendants an evidentiary hearing on juror misconduct, but reversed the portion of the judgment as to the mail fraud statute and remanded for further consideration as to whether the evidence established a scheme to defraud the United States.

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