White Collar Roundup - September 2013

In United States v. DiMasi, the U.S. Court of Appeals for the First Circuit, with Associate Justice (Ret.) David H. Souter sitting by designation, affirmed the bribery conviction of former speaker of the Massachusetts House of Representatives Salvatore DiMasi. On appeal, DiMasi, who had been sentenced to a term of imprisonment of 96 months, argued his sentence was substantively unreasonable. DiMasi claimed the sentencing court sentenced him more harshly than others, punished him for post-verdict public statements of disagreement with the verdict and punished him for being the third consecutive Massachusetts House speaker to be convicted of a federal crime. The First Circuit rejected these claims, finding the district court did not abuse its discretion when sentencing him. In rejecting DiMasi's arguments, the court noted that "the district court observed that the shorter sentences received by his predecessors might have actually emboldened DiMasi." Neither of the prior