United States v. Del Valle
2012 U.S. App. LEXIS 5733
| 7th Cir. | 2012Background
- Sanchez rose to lead Chicago's Department of Streets and Sanitation and helped found the Hispanic Democratic Organization (HDO).
- The HDO mobilized city employees and volunteers to obtain city jobs in exchange for campaign work, in violation of Shakman decrees prohibiting patronage hiring.
- The city’s hiring process involved budget approval, public postings, applicant screening and scoring, interviews, and certification by a hiring authority that politics did not influence decisions.
- The IGA acted as the city’s liaison, receiving vacancy lists and recommending preferred candidates, with its selections ultimately funded by city departments.
- Sanchez directed staff to falsify ratings and interview records and to certify nonpolitical hiring, while Del Valle used his coordinator role to influence who received city jobs; both were charged after a long investigation.
- During retrial, Sanchez testified about his work ethic and good standing, triggering cross-examination about prior incidents; Del Valle’s testimony showed his significant influence over hiring decisions; ultimately Sanchez was convicted of one mail fraud count and Del Valle of perjury.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence of drunken-driving incidents was admissible and harmless | Sanchez argues the evidence was prejudicial and improper | Sanchez contends the evidence was irrelevant and unduly prejudicial | Harmless error; not enough to affect verdicts given strong other evidence |
| Whether the improper curative instruction was reversible error | Sanchez claims the instruction magnified prejudice | Court properly instructed to disregard and error was limited | Harmless error; no reversal given extensive other proof |
| Whether the indictment adequately alleged deprivation of money or property under mail fraud | Sorich approach requires deprivation of money/property; city jobs are property | Jobs are property or the salary is money; deprivation shown | Indictment sufficient; city jobs are money or property for mail fraud |
| Whether the district court properly denied severance for Del Valle | Del Valle argues joint trial violated fair trial rights due to evidence disparity | Severance wasn’t required; instructions mitigated spillover | No abuse of discretion; severance denied |
Key Cases Cited
- United States v. Stallworth, 656 F.3d 721 (7th Cir.2011) (evidentiary rulings reviewed for abuse of discretion; harmless error standard)
- United States v. Garcia, 986 F.2d 1135 (7th Cir.1993) (harmless-error review for evidentiary rulings)
- United States v. Cooper, 591 F.3d 582 (7th Cir.2010) (harmless error standard for evidentiary rulings)
- United States v. James, 487 F.3d 518 (7th Cir.2007) (limiting instructions presumed to be followed by jurors)