United States v. Clayton R. Jackson

Clayton Jackson was convicted of racketeering ( 18 U.S.C. § 1962 (c)), conspiracy to commit mail fraud and money laundering ( 18 U.S.C. §§ 1956 and 1341), and mail fraud ( 18 U.S.C. § 1341 ) for his part in offering bribes to California state Senator Alan Robbins and establishing a money laundering scheme to funnel the money fraudulently obtained from Jackson’s clients to Robbins through California state Senator Paul Carpenter. He appeals.

Jackson’s primary contention is that existing caselaw requires the jury to find an explicit quid pro quo to convict Jackson of the racketeering charges predicated on violation of a California bribery statute. The appeal also asserts instructional errors and evidentiary shortcomings, none of which justifies reversal. We affirm.

I. BACKGROUND

Clayton Jackson, a prominent lobbyist for the insurance industry, was indicted in a sweeping federal investigation of corruption in Sacramento. Senator Alan Robbins, who was convicted on similar charges, was the Chairman of the Senate Insurance Committee. The following summaries set out the facts underlying each of Jackson’s convictions.

A. Racketeering Act 4 — Senate Bill 1719

In Racketeering Act 4, the…