Thursday, March 14, 2019

Some thoughts on Manafort's NY charges

From former federal and NY prosecutor, Daniel Alonso:



On #3, because the jury hung and the defense sought a mistrial, those charges are highly likely *not* to be subject to 's expansive "transaction test" for double jeopardy. On #1 and #2, question is whether the federal counts and NY counts have at least 1 different element (they do), AND whether they were "designed to prevent very different kinds of harm or evil."

For falsifying business records, there's a very good argument (likely correct) that that charge was to prevent a very different harm/evil than federal bank fraud, since no federal analogue was charged. (Counterargument is false records charge requires "intent to defraud").

For #1, bank frauds for which Manafort *was* convicted, it's a tougher road for . Argument that DA will have to win is that mortgage fraud was designed for different harm than bank fraud.

...but hey, do what you want...you will anyway.

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