D.C. Circuit, on 2-1 Vote, Upholds Conviction of Jan. 6 Attacker on Grounds He Acted “Corruptly” in Obstructing Proceedings; Implications for Trump Prosecution

You can find the majority opinion (by two Democratic-appointed judge) and the dissent (by a Republican-appointed judge) at this link.

To oversimplify things a bit, the majority defined “corruptly” to include acting unlawfully. The dissenter viewed the term as applying to a benefit that was financial, professional, or exculpatory.

Notably, even under the dissent’s definition, Trump’s alleged post-2020 election conduct in attempting to manipulate state elected and election officials, and DOJ, so that he could stay in office despite losing would fit as both unlawful conduct under the majority view and as conduct that provided him a professional benefit under the dissent’s view.

This case, however, could be bound for an en banc decision at the D.C. Circuit, or the Supreme Court. I expect the Court will ultimately have to resolve this issue for the Jan. 6 defendants.

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