United States v. Parker

Joann Parker (defendant) worked as a clerk to administrative-law judge John Aronson at the Social Security Administration (SSA) Office of Hearings and Appeals. Aronson held hearings that determined whether individuals qualified for certain government benefits, including Supplemental Security Income (SSI). Joann assisted Aronson by recording and notetaking during the hearings and typing and mailing Aronson’s decisions after hearings. Joann did not have authority to grant or deny benefits or to sign Aronson’s name. However, she had access to the office computer system containing applicant information and letters granting and denying benefits. Joann helped multiple applicants with pending appeals fraudulently obtain SSI benefits in exchange for payment. She was assisted by two other SSA employees and her husband, Ralph Parker (defendant). Joann and Ralph were indicted for public bribery and conspiracy to commit public bribery in violation of federal law. At trial, the government sought to introduce a telephone conversation between Peggy Kelly and the Parkers. Joann had called Kelly, and a man on Joann’s end of the line interrupted the call, referred to Joann as his “old lady,” and threatened Kelly. Kelly testified that she believed the man was Ralph but admitted that she had not met him previously and could not identify his voice. Ralph objected to the introduction of conversation as evidence against him on authentication grounds. The district court overruled the objection and admitted the conversation into evidence. Joann and Ralph were both convicted for public bribery and conspiracy to commit public bribery. They appealed on multiple grounds, contesting, among other things, the admission of the phone conversation and whether Joann could be liable for public bribery for acts outside her scope of authority.