United States v. Peter Chong

Peter Chong appeals his conviction on murder-for-hire and extortion counts stemming from his involvement with the Wo Hop To gang in Northern California. Chong’s main contention is that the jury-had insufficient evidence to convict him for his role in the attempted murder of a leader of a rival gang in Boston. He argues that the government failed to link him to the attempted murder or demonstrate that he offered anything of pecuniary value to the hitmen in exchange for commission of the murder — a required element of the offense.

We conclude that the jury had insufficient evidence to convict Chong on the murder-for-hire offense because the government failed to prove that Chong — or one of his co-conspirators — promised anything of pecuniary value to the hitmen as a quid pro quo for murdering a gang rival.

I.

Chong came to the United States in 1982 purportedly to set up and promote a Chinese opera in this country. In the late 1980s and 1990s, Chong became involved with illicit gang activity through his membership in — and eventual leadership of— the Wo Hop To, an organized crime gang in Northern California.

Chong and his gang engaged in loan sharking and exerted control over…