Case Explained: USA V. RIDLEY-THOMAS

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-08-03 Docket: 2:21-cr-00485- The ninth-circuit affirmed Mark Ridley-Thomas’s convictions for one count of conspiracy in violation of 18 U.S.C. § 371, one count of bribery concerning programs receiving federal funds in violation of 18 U.S.C. § 666(a)(1)(B), and five counts of honest services mail and wire fraud in violation of 18 U.S.C. §§ 1341, 1343, 1346, and 2(b). The court held that the service of funneling $100,000 from Ridley-Thomas’s campaign fund through the University of Southern California to United Ways for the benefit of his son constituted a “thing of value” sufficient to support convictions under both § 1346 and § 666. The court rejected the argument that honest services fraud requires personal enrichment or tangible benefits, noting that the statute does not require each participant in the scheme to personally benefit. Regarding materiality, the court found sufficient evidence that the deception was material because it naturally tended to lead other decision-makers to change their conduct, and direct evidence of constituent disapproval was not required. The court also rejected challenges to jury instructions, finding no error in the definitions of intent, quid pro quo, or lawful ingratiation. Finally, the court declined to extend *Batson v. Kentucky* to intersectional claims based on race and gender, concluding that the district court did not clearly err in rejecting Ridley-Thomas’s challenge to peremptory strikes against Black female jurors. The convictions stand and Ridley-Thomas remains subject to sentencing. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.