Media magnate Conrad Black [CBC profile; JURIST news archive] was ordered to return to prison by the US District Court for the Northern District of Illinois [official website] on Friday, to serve 13 more months of his 42 month sentence. Judge Amy St. Eve [official profile], his original sentencing judge, said that although she was impressed by Black's rehabilitative efforts in prison, the sentencing guidelines mandated he serve his full sentence. Black was released on bond [JURIST report] last July after a Supreme Court ruling [opinion, PDF, JURIST report] in Black v. United States [Cornell LII backgrounder] constricted the application of the "honest services" doctrine [18 USC § 1346 text] only to cases of bribery and kickbacks. The US Court of Appeals for the Seventh Circuit [official website] then vacated [opinion, PDF; JURIST report] Black's two "honest services"-based convictions, but upheld counts of fraud and obstruction of justice, remanding the case to the Northern District of Illinois for re-sentencing. The re-sentencing hearings began in January [JURIST report]. Black may not return to prison for up to two months.
Last month, the US Supreme Court [official website; JURIST news archive] denied certiorari [JURIST report] in Black v. United States [docket; cert. petition, PDF] in which Black was seeking to have his remaining conviction overturned. Black was originally convicted on two counts of fraud and a third count of obstruction of justice after a jury acquitted him and his co-defendants of 15 other fraud counts. He appealed to the Supreme Court, which remanded [JURIST report] the case to the Seventh Circuit.