U.S. v. Calk: 18 U.S.C. Section 215 and Perspective Rolls

In a case of first impression in the Second Circuit regarding 18 U.S.C. Section 215, a panel has affirmed the conviction of Stephen Calk. Calk facilitated The Federal Savings Bank's ("TFSB") approval of significant loans to Paul Manafort in exchange for Manafort's assistance in securing positions for Calk in the Trump Campaign and, later, the Trump Administration. Calk was TFSB's CEO. The Trump Administration position did not pan out, despite Calk's submission of a a professional biography and document entitled “Stephen M. Calk Perspective Rolls in the Trump Administration." The Court held that Calk's assistance was a "thing of value" within the meaning of the statute and that Calk's conduct in facilitating the loans was "corrupt" under the statute.

Here is the opinion.

(wisenberg)