United States v. Ralph F. Vitale

WINTER, Circuit Judge.

Ralph F. Vitale appeals from his conviction and sentence entered after a jury found him guilty of bank fraud in violation of 18 U.S.C. §§ 1344(1) and (2). Vitale participated in a scheme with Charles Hoblin and Peter Trantino to submit fraudulent business loan applications to Fleet Bank. Vitale principally argues that: (i) the district court violated his Sixth Amendment right to confront and cross-examine a witness by denying him access to the witness’ substance abuse treatment records; (ii) the district court erred in refusing to conduct a post-trial inquiry into juror…