Case Explained: Non-Argument Calendar UNITED STATES OF AMERICA v. ANGELA CHEW

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-07-27 Docket: 6:23-cr-00214-GAP-RMN-1 The Eleventh Circuit affirmed Angela Chew’s convictions for conspiracy to bribe a public official, bribery of a public official, and wire fraud. The court held that the district court did not abuse its discretion in denying Chew’s third motion for a continuance because she failed to demonstrate specific, substantial prejudice resulting from the denial; the record showed her counsel had ample time to prepare over ten months, and the excluded exhibits would not have indicated a different outcome given the overwhelming evidence of guilt. Regarding the motion for judgment of acquittal, the court applied de novo review and found sufficient evidence existed under 18 U.S.C. § 201(a)(1) to support the jury’s finding that Chew was a “public official,” as the statute broadly defines any federal agency employee acting in an official function as such, regardless of whether the position is high-level or involves managerial discretion. Finally, the court declined to review Chew’s challenge to the jury instructions regarding the definition of a public official under 18 U.S.C. § 201(b)(2) because the doctrine of invited error precluded appellate review, as Chew and the government had jointly proposed the instruction that was given. The practical consequence is that Chew’s convictions stand and her 96-month prison sentence remains in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.