Monday, December 23, 2013

United States v. DeCastris case brief

United States v. DeCastris case brief summary
798 F.2d 261 (1986)

Defendant challenged his conviction from the United States District Court for the Northern District of Illinois for mail fraud, in violation of 18 U.S.C.S. § 1341Defendant contended that his conduct was not mail fraud because the state statute and the disability forms he filled out were ambiguous as to the reporting requirements surrounding "assuming" and "resuming" employment.

Defendant was a police officer, and in addition, held another full-time job. Defendant eventually began receiving disability payments, and on his disability paperwork, periodically denied that he had "assumed" or "resumed" work, because he had been employed at his second job prior to and continuing through the period for which he received disability. Defendant was charged with mail fraud under 18 U.S.C.S. § 1341, and he was convicted.


  • On appeal, defendant alleged that his conduct did not amount to mail fraud, because the state statute and the required disability forms were ambiguous. 
  • The court held that mail fraud was merely a fraudulent "scheme" facilitated by use of the mails, and therefore defendant's conviction was not improper. 
  • Defendant also contended that the district court erred by admitting evidence of ongoing falsehoods made by defendant contained in various written documents, because these "other wrongs" prejudiced the jury. 
  • The court held that under Fed. R. Evid. 404(b), such information was admissible to show intent, and therefore the district court did not err in allowing the evidence at defendant's trial. 
  • The court therefore affirmed defendant's conviction.

The court affirmed defendant's conviction for mail fraud resulting from misleading disability claim filings. The court held that because mail fraud is merely a fraudulent scheme facilitated by the use of the mails, and the jury was properly instructed, and found that defendant had intended to defraud, defendant's conviction for mail fraud was not improper.

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