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Sawyer pled guilty to one count of honest services fraud and served a six month prison sentence. Following the Supreme Court's decision in Skilling, Sawyer filed a motion of coram nobis to vacate his conviction on grounds that the conduct constituting the conviction no longer fell within the definition of honest services fraud. The government did not oppose the motion and, on February 1, 2011, District Court Judge England set aside and vacated the conviction in its entirety.
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