United States v. Phillips

Defendant appealed his conviction for conspiracy to use interstate telephone calls in the commission of a murder-for-hire in violation of 18 U.S.C. 1958. The Ninth Circuit affirmed the district court's conclusion that defendant's promise to forgive an uncollectable debt satisfies the pecuniary value requirement of section 1958.The panel held that the pecuniary value requirement does not require the murder-for-hire agreement to comport with contract rules, as Congress did not aim section 1958 only at murderous businessmen. In this case, defendant's promise of loan forgiveness satisfied section 1958's pecuniary value requirement. In so holding, the panel joined its sister circuits' understanding that section 1958 does not require that the promised economic advantage be enforceable. View "United States v. Phillips" on Justia Law