The Supreme Court denied certiorari in Black v. United States [docket; cert. petition, PDF] in which Black was seeking to have his remaining conviction overturned. Black was originally convicted on two counts of fraud and a third count of obstruction of justice after a jury acquitted him and his co-defendants of 15 other fraud counts. He appealed to the Supreme Court, which remanded [JURIST report] the case to the US Court of Appeals for the Seventh Circuit [official website] to apply a different standard for the two fraud counts. The Seventh Circuit vacated [JURIST report] the conviction for the fraud counts but left intact the obstruction of justice claim. Black argued that in applying the incorrect standard to the fraud counts had created error that should overturn his conviction on the remaining count because of the relation of the charges. Justice Elena Kagan did not take part in the decision to deny certiorari. Black said that he was not surprised [Canadian Business report] that the Supreme Court did not take another look at his case.