## Facts

- Louisiana implemented a limited licensing system for riverboat casinos through state regulatory authorities.
- Edwin Edwards, a long-time Louisiana politician and former governor, and his associates were accused of exploiting Edwards’s perceived ability to influence the licensing process.
- After leaving office, Edwards returned to private practice and worked closely with his son, Stephen Edwards, an attorney.
- The prosecution alleged multiple schemes in which riverboat license applicants were solicited for substantial payments in exchange for “help” with favorable licensing outcomes.
- Applicants were led to believe that refusal to pay would result in adverse action, including loss of any realistic chance of receiving a license or increased regulatory obstruction.
- Cecil Brown (titled “Special Assistant to the Governor”), Andrew Martin (a former “Executive Assistant to the Governor”), and Bobby Johnson (a close Edwards associate) allegedly participated in demanding or facilitating payments connected to the licensing process.
- A federal jury convicted Edwin and Stephen Edwards and several associates of offenses including Hobbs Act extortion, mail and wire fraud, money laundering, false statements, and RICO violations after a joint trial involving multiple schemes.

## Issues

1. Whether sufficient evidence supported convictions for Hobbs Act extortion “under color of official right” and through fear where the scheme traded on Edwards’s influence and he was not always a sitting officeholder during relevant events.
2. Whether the evidence and jury instructions supported RICO convictions, including proof of an enterprise, a pattern of racketeering activity, and predicate acts tied to the licensing schemes.
3. Whether the district court committed reversible error in evidentiary and trial-management rulings, including admitting recordings, co-conspirator statements, and contextual evidence about Edwards’s political prominence, and denying severance or mistrial requests.

## Decision

- The Fifth Circuit affirmed all convictions, finding no reversible error.
- The court held the evidence was sufficient for extortion convictions where payments were solicited in exchange for Edwards’s apparent ability to influence governmental decisionmaking and where applicants reasonably feared adverse consequences for nonpayment.
- The court upheld the RICO convictions, concluding the jury could find an enterprise centered on the Edwards network and a pattern of related racketeering acts across multiple licensing schemes.
- The court rejected evidentiary and procedural challenges, concluding the district court acted within its discretion and any risk of spillover prejudice was addressed through trial structure and limiting instructions.

## Legal Principles

- Hobbs Act extortion “under color of official right” may be established by proof that defendants wrongfully obtained payments by trading on perceived governmental power or access to decisionmakers; the relevant focus is exploitation of apparent official influence rather than formal title alone.
- Extortion through fear may be supported where victims are led to believe nonpayment will result in adverse official treatment affecting valuable government benefits.
- RICO liability may rest on multiple related acts (including extortion and mail/wire fraud) carried out through an association-in-fact enterprise and forming a continuing pattern directed at multiple victims over time.
- On sufficiency review, an appellate court views the evidence in the light most favorable to the verdict and asks only whether a rational jury could find the elements beyond a reasonable doubt.
- Trial courts have discretion to admit contextual evidence explaining why victims would credit a defendant’s influence and to admit co-conspirator statements and recordings when foundational requirements are met; severance is not required absent a showing of compelling prejudice.

## Conclusion

The Fifth Circuit affirmed convictions arising from schemes to monetize perceived political influence over Louisiana’s riverboat casino licensing, holding that the evidence supported Hobbs Act extortion and RICO findings and that the district court’s evidentiary and trial-management rulings did not warrant reversal.


United States v. Edwards, 303 F.3d 606 (5th Cir. 2002)