[JURIST] An appeals court on Wednesday rejected convicted former Illinois governor George Ryan's appeal seeking to overturn his 2006 conviction on corruption charges. The 77-year-old Ryan was convicted [JURIST report] in 2006 on multiple counts of corruption and fraud [indictment, PDF] in connection with a bribes-for-licenses scandal that occurred during Ryan's term as Illinois Secretary of State. Ryan appealed his conviction after the US Supreme Court [official website; JURIST news archive] decision in Skilling v. United States [Cornell LII backgrounder; JURIST report ] that the "honest services" doctrine [18 USC § 1346 text] is not unconstitutionally vague when construed narrowly. Ryan brought a collateral attack arguing that he was convicted under pre-Skilling jury instructions, and under this new "honest services" precedent, he should be released from prison and his convictions for mail fraud and for violations of the Rackteer Influenced Corrupt Organizations (RICO) [18 USC § 1961 et seq.] should be thrown out. But Judge Frank Hoover Easterbrook held, "there is no doubt that a properly instructed jury could have deemed the payments bribes or kickbacks; the inference that they were verges on the inescapable. The district court's opinion canvasses the evidence and demonstrates why a reasonable jury could find that Ryan sold his offices to the high bidders." Last year, District Judge Rebecca Pallmeyer rejected Ryan's appeal holding that the different instructions were harmless error.
Illinois has two convicted former governors as Rod Blagojevich [personal website; JURIST news archive] was convicted [JURIST report] on 17 of 20 counts including attempting to sell or trade the US Senate seat vacated by President Barack Obama. Blagojevich had also tried to cite Skilling, but a district judge denied a request [JURIST report] to delay the trial. In 2008, Ryan issued his first public apology [JURIST report] for the crimes that resulted in his imprisonment. Ryan was sentenced in 2007 and jailed [JURIST reports] on corruption charges. Ryan's trial began in 2005, and, in 2006, a jury found him guilty [JURIST reports] on multiple counts of corruption and fraud [indictment, PDF] in connection with a bribes-for-licenses scandal that occurred during Ryan's term as Illinois Secretary of State. Ryan made national headlines and won praise in some quarters in January 2003 when, just before leaving office, he commuted the executions [BBC report] of all Illinois inmates then on death row.