United States v. White, 663 F.3d 1207

Jefferson County sewer project required ~$3B to fix; bribery schemes tied to U.S. Infrastructure and its executive Singh.
White became Jefferson County Environmental Services supervisor in 2002 and could influence contract approvals.
Singh paid White at least $22,000 in cash (2003–2005) for favorable treatment of U.S. Infrastructure.
From 2003–2005, Jefferson County awarded 48 contracts to U.S. Infrastructure totaling $1,107,755.55 in professional fees.
Indictment charged White with conspiracy (Counts 1, 10) and multiple federal‑funds bribery counts (Counts 2–9, 11) and forfeiture (Count 12); he was convicted on Counts 1–9, with Counts 10–11 acquitted; sentence imposed was 120 months concurrent with other terms; White appeals challenging sufficiency of the evidence and reasonableness of the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for bribery counts	White argues the cash bribes lacked corrupt intent.	White contends payments were not for contracts; insufficient nexus.	Sufficient evidence showed corrupt intent and benefit from the bribes.
Sufficiency of evidence for conspiracy	Evidence shows an agreement to commit bribery.	No explicit, direct agreement proven; circumstantial evidence insufficient.	Evidence demonstrates an agreement and participation sufficient for conspiracy.
Causation for the 16-level enhancement	Professional fees were the return for bribes; exceed $1,000,000.	Fees were pre-existing contracts; not proven to be in return for bribes.	Evidence supports that fees were received in return for bribes; enhancement upheld.
Potential double counting of enhancements	Elected official status and base level adjustments double-counted.	Double counting allowed given distinct harms of elected office.	Not impermissible double counting; allowed due to different harms of public service.
Reasonableness of sentence under §3553(a)	Guidelines range 188–235 months; 120 months too lenient.	Sentence reflects seriousness, deterrence, and public trust.	120-month sentence is reasonable and within district court discretion.

U.S. v. Hill, 643 F.3d 807 (11th Cir. 2011) (sufficiency standard of review for evidence)
U.S. v. McNair, 605 F.3d 1152 (11th Cir. 2010) (corrupt intent and statutory construction for §666 bribery)
U.S. Infrastructure, Inc., 576 F.3d 1195 (11th Cir. 2009) (evidence of bribes and contracts; circuit treatment of conspiracy evidence)
U.S. v. Polar, 369 F.3d 1248 (11th Cir. 2004) (sentencing/fact-finding review standards)
U.S. v. Dudley, 463 F.3d 1221 (11th Cir. 2006) (double counting principle in sentencing)
U.S. v. Siegelman, 640 F.3d 1159 (11th Cir. 2011) (application of §666 in bribery contexts; Skilling note context)
U.S. v. Langford, 647 F.3d 1309 (11th Cir. 2011) (chapter on corruption and sentencing within the circuit)
U.S. v. Irey, 612 F.3d 1160 (11th Cir. 2010) (en banc review of reasonableness standards)
U.S. v. Pugh, 515 F.3d 1179 (11th Cir. 2008) (§3553(a) factors guiding substantive review)