United States v. Ganim

Joseph P. Ganim (defendant) was the mayor of Bridgeport, Connecticut, from 1991 to 2003. In 1996, Ganim formed a plan with Ganim’s media advisor, Leonard Grimaldi, and Ganim’s driver and aide, Paul Pinto. Ganim offered to steer public contracts to Grimaldi’s and Pinto’s clients, and Grimaldi and Pinto agreed to evenly split any consulting fees that they earned. In exchange, Grimaldi and Pinto covered many of Ganim’s expenses, and Grimaldi hired and overcompensated Ganim’s wife. For example, Ganim selected Professional Services Group (PSG) as a contractor to help privatize Bridgeport’s wastewater-treatment facilities. PSG hired Grimaldi as a consultant and paid Grimaldi $311,396 in consulting fees from 1997 to 1999. In the same contract bid, Pinto represented the Lenocis, a father-son business team and Ganim’s political benefactors. Grimaldi ensured that PSG diverted $70,000 per contract year to Pinto and the Lenocis. Then Grimaldi and Pinto used some of their profits from PSG’s public contract to provide Ganim with entertainment, meals, clothes, and other benefits. Based on these and other acts, the federal government (plaintiff) prosecuted Ganim in the United States District Court for the District of Connecticut, and the jury convicted Ganim of several crimes, including extortion in violation of the Hobbs Act, federal programs bribery in violation of 18 U.S.C. § 666(a)(1)(b), honest-services mail fraud, and bribe receiving in violation of Connecticut state law (the bribery-related crimes). Ganim appealed to the United States Court of Appeals for the Second Circuit. Ganim argued in relevant part that the jury was improperly instructed regarding the quid pro quo element of the bribery-related crimes.