Theft from a City Receiving Federal Funds

United States v. Michael Spano, Sr. et al, Case No. 03-1110 (03/24/2005): The defendants were convicted of violating 18 U.S.C. §666, which prohibits theft from an organization receiving federal funds, as well as bribery of officials of organizations receiving federal funds. The defendants argued that there had to be some nexus between the stolen funds (or bribes) and the federal grants. In Sabri v. United States, 124 S. Ct. 1941 (2004), the Supreme Court had held the statute constitutional on its face, and the Seventh Circuit relied on Sabri to hold that there was no nexus requirement.