JURIST - Paper Chase: Conrad Black released from prison

[JURIST] Media magnate Conrad Black [CBC profile; JURIST news archive] was released from federal prison in Florida Friday but remains in US custody pending removal proceedings. It remains unclear [National Post report] how long Black will be held by US officials or where he will be deported. He is a UK citizen, but he has been granted at a temporary resident permit by the Canadian government and he has expressed a desire to return to Toronto. Black was ordered to return to prison [JURIST report] last summer to serve 13 more months of his 42-month sentence. He was released on bond [JURIST report] in 2010 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.

Last May the US Supreme Court [official website] 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.