United States v. Quintanilla, 114 F.4th 453

Defendants Arturo Cuellar (AC) and Ricardo Quintanilla were convicted on multiple federal charges—primarily honest-services fraud, bribery, and money laundering—arising from their roles in a scheme to bribe Weslaco, Texas city commissioners to steer water infrastructure contracts to specific firms.
The bribery scheme involved payments funneled through intermediaries, where city officials accepted cash in exchange for contract decisions, and shell entities and consulting agreements were used to disguise the nature of the payments.
Both were convicted by jury and received lengthy sentences, heavy fines, and ordered restitution/forfeiture. The case was tried in the Southern District of Texas before Judge Alvarez, whom Cuellar challenged for potential bias due to an old civil matter.
On appeal, defendants raised numerous challenges—indictment sufficiency, constructive amendment, judicial bias, evidentiary rulings, sentencing calculations, and alleged obstruction of justice enhancements.
The Fifth Circuit sifted through both the substance and procedural adequacy of defendants' arguments, noting many were either inadequately briefed, forfeited, or otherwise non-meritorious.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constructive amendment of indictment	No constructive amendment occurred.	Indictment constructively amended by evidence/theory shifts at trial.	No amendment; any such claim not properly briefed.
Sufficiency of indictment and evidence	Indictment and evidence suffice under established standards.	Counts require property interest and are unconstitutionally vague.	Indictment and evidence are sufficient.
Judicial recusal (bias of Judge Alvarez)	No bias warranting recusal; prior litigation insignificant.	Prior lawsuit and settlement raise questions about impartiality.	Reasonable observer would not doubt impartiality.
Exclusion of evidence/expert testimony	Rulings were within discretion; evidence was untimely/irrelevant.	Exclusion deprived defendants of a fair trial/right to defense.	No abuse of discretion; exclusions were appropriate.
Sentencing calculation and enhancements	Sentencing, forfeiture, restitution, and enhancements proper.	Errors in sentencing (base levels/amounts/obstruction enhancement).	Sentencing determinations affirmed.
Application of Snyder v. United States	Snyder about gratuities, not bribes; this case involves bribes.	Snyder impacts the conviction due to outside employment/gratuities language.	Snyder does not apply; this case involves bribes.

Skilling v. United States, 561 U.S. 358 (defines honest-services fraud and limits to bribe-and-kickback schemes)
Hamling v. United States, 418 U.S. 87 (sets out minimum sufficiency requirements for indictments)
Kelly v. United States, 140 S. Ct. 1565 (discusses limits of federal fraud statutes but found not applicable here)
Ciminelli v. United States, 598 U.S. 306 (distinguishes between property rights and intangible rights such as honest services)
McNally v. United States, 483 U.S. 350 (origin of the honest-services doctrine debate; abrogated by later statute)
United States v. Olano, 507 U.S. 725 (plain error review standard for unpreserved claims)
Anderson v. City of Bessemer City, 470 U.S. 564 (deference to trial court factual findings under clear error review)