Federal appeals court overturns Dallas City Hall bribery conviction

The Fifth Circuit Court of Appeals on Tuesday threw out the federal bribery conviction of Dallas developer Ruel Hamilton, saying the jury was not properly instructed on the requirements of the law. The Dallas jury convicted Hamilton in June 2021 of bribing Dwaine Caraway and Carolyn Davis with money when they were on the City Council to help his low-income housing developments. The Fifth Circuit said the jury was improperly told a “quid pro quo,” or some benefit in exchange for the money, was not necessary to convict. The money Hamilton gave the council members was a gratuity and not quid pro quo bribes as required by the law, the judges wrote in their opinion. The ruling struck a blow to federal public corruption cases.

It was not immediately clear Tuesday evening whether it could affect recent bribery convictions like the one involving a former Richardson mayor, Laura Jordan, who was sentenced to six years in prison earlier this month. Hamilton, 65, was sentenced in November 2021 to eight years in federal prison. But he was granted extra time to report to prison due to ongoing health problems and never began his sentence. It will be up to the U.S. attorney’s office to decide whether to retry him. A spokeswoman said the office did not have any comment. Hamilton’s attorney declined to comment Tuesday and attorneys for Caraway and Davis could not be reached for comment. With its opinion, the Fifth Circuit is now in the minority, having joined two other circuits in the U.S. that said the federal bribery statute in question criminalizes only quid pro quo bribes and not gratuities. Five other federal circuits have ruled that the law covers both bribes and illegal gratuities.