United States v. Sanjaya Bahel

Tried in the Southern District of New York, this case had been pending on appeal in the Second Circuit prior to the Supreme Court’s decision in Skilling. Bahel was a procurement officer at the United Nations and was charged with providing favorable treatment to Indian companies that submitted bids for contracts with the U.N. and with bribes and gratuities for receiving financial benefits from the companies. He was convicted of five counts of honest services fraud and one count of 18 U.S.C. 666.