The government's case, even in Counts 8 and 9, was always primarily focused on the pay-to-play scheme between Scrushy and Siegelman. The vast majority of the allegations and testimony went to prove this scheme. The government always described the scheme alleged in Counts 8 and 9 as selfdealing, and its attempt now—post-Skilling—to emphasize the alleged bribery of Adams finds some, but not much, support in the proof. The evidence that Adams intended to alter his official actions as a result of the receipt of benefits from Scrushy is insufficient, and Scrushy's convictions on Counts 8 and 9 must be reversed.

Last June, the Supreme Court vacated the 2006 judgments [JURIST report] against Siegelman and Scrushy. Their cases were remanded to the Eleventh Circuit for proceedings consistent with the court's ruling in Skilling v. United States [opinion, PDF; JURIST report]. Siegelman and Scrushy were convicted in 2006 [JURIST report] on federal bribery and corruption charges. The convictions were appealed, and Siegelman had two counts of mail fraud reversed for lack of evidence. The court of appeals later denied a request [JURIST report] by Siegelman and Scrushy for an en banc rehearing of their convictions on charges of corruption.