United States v. Hoskins (2d Cir. August 2022)
Fraud Cases, Jury Instructions, Recent Circuit Cases, Second Circuit, Speedy Trial|
The Second Circuit affirmed a district court’s order acquitting a defendant of violations of the Foreign Corrupt Practices Act, holding that the defendant, who worked for a U.K. subsidiary of a U.S. company involved in bribing Indonesian officials, was not an “agent” or employee” of the U.S. company under common law. The Court also held that the defendant’s speedy trial rights were not violated by a 6-year delay and that the trial court did not err in instructing the jury on withdrawal from a conspiracy and proving venue in a case involving money transfers through multiple states.