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In the Courts

By ljnstaff | Law Journal Newsletters
May 02, 2017

Third Circuit Affirms Issues Opinion Clarifying 'Official Act' in PA Bribery Case

On March 28, 2017, a three-judge panel in the U.S. Court of Appeals for the Third Circuit affirmed the conviction and 42-month sentence of Ronald Repak, the Executive Director of the Johnstown Redevelopment Authority (JRA), for violating two counts of extortion under the Hobbs Act, 18 U.S.C. § 1951, and two counts of federal program bribery, 18 U.S.C. § 666. In its published opinion, the Third Circuit applied recent Supreme Court precedent in McDonnell v. U.S. to determine that Repak's actions constituted an “official act” under the federal bribery statute. Repak had accepted gifts and free personal contracting services from contractors who were working on JRA projects in exchange for awarding them JRA contracts.

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