United States v. Richard C. Jewell

FARRIS, Circuit Judge:

Jewell, an employee of the United States Bureau of Land Management, was convicted of thirteen counts of having a personal interest in a government contract, in violation of 18 U.S.C. § 208(a), and one count of conspiracy, in violation of 18 U.S.C. § 371.

On appeal, Jewell argues first that the prosecution multiplied a single violation of 18 U.S.C. § 208(a) into thirteen separate counts. Section 208(a) makes criminally liable

whoever ... participates personally and substantially as a Government officer or employee, through decision, approval, disapproval, recommendation,…