United States v. Renzi

If a member of Congress offers evidence of his own legislative acts at trial, the government is entitled to introduce rebuttal evidence narrowly confined to the same legislative acts.

Former Arizona Congressman Richard Renzi misappropriated his insurance clients’ funds to finance his campaign and then lied to the clients and other insurance regulators. The district court found him guilty of public corruption charges, racketeering charges, and insurance fraud charges. Renzi, along with his co-defendant James Sandlin, contend that there was insufficient evidence for the court to support the verdict. On appeal, Renzi first argued against the government’s extortion and fraud convictions on the grounds that he and his partner had failed to receive anything of value in the exchange that allegedly took place, contending that the party he entered into the deal with received an equal value exchange. The panel rejected that argument affirming the district court’s calculation of the value of the payment. Renzi next argued that the court erred in allowing testimony from his District Director under the Congressman’s Speech and Debate Privilege. However, the panel held that if a member of Congress offers evidence of his own legislative acts at trial, the government is entitled to introduce rebuttal evidence narrowly confined to the same legislative acts, and such rebuttal evidence does not constitute questioning the member of Congress in violation of the Speech and Debate Clause. Renzi also contends that he was denied his right to present a complete defense because the court excluded certain classified documents. However, the panel ruled that the district court did not abuse its discretion when it disallowed Renzi to present the documents because they contained limited relevance. The panel also found that the district court correctly allowed certain testimony and that there was sufficient evidence to charge Sandlin. AFFIRMED.