Bravo-Fernandez v. United States

Juan Bravo-Fernandez (defendant) was indicted for bribery in federal district court after paying for Hector Martínez-Maldonado, a Puerto Rican senator, to see a Las Vegas boxing match. The indictment charged Bravo-Fernandez with federal bribery and conspiracy. The indictment also charged Bravo-Fernandez with violating the Travel Act, which prohibited interstate travel for a criminal purpose. A jury convicted Bravo-Fernandez of bribery but acquitted him of conspiracy and violating the Travel Act. Later, the United States Court of Appeals for the First Circuit vacated the conviction because the district court did not properly instruct the jury regarding what the government needed to prove. The appeals court remanded the case, and the district court entered an acquittal. However, that order was vacated after the government clarified that the appeals court’s decision vacating the conviction did not require that the district court enter an acquittal. The district court then entered an order vacating the conviction. Bravo-Fernandez moved to reinstate the initial acquittal, arguing that it could not be rescinded under the Double Jeopardy Clause. The district court denied the motion. Bravo-Fernandez moved again for an acquittal, arguing that the original acquittals for the conspiracy and Travel Act charges meant that the government could not relitigate the bribery charges, because a jury had decided that the government failed to prove elements that were necessary for a bribery conviction. The district court denied the motion, and the appeals court affirmed. Bravo-Fernandez appealed to the United States Supreme Court, which granted certiorari.