[JURIST] The US Court of Appeals for the Seventh Circuit [official website] on Monday upheld [opinion, PDF] a lower court’s denial of motion submitted by former Illinois governor George Ryan [JURIST news archive] seeking his release from prison. Ryan argued that he was convicted under pre-Skilling v. United States [Cornell LII backgrounder; JURIST report] jury instructions and thus he should be released from prison and his convictions for mail fraud and for violations of the Rackteer Influenced Corrupt Organizations (RICO) [18 USC § 1961 et seq.] should be thrown out. The court ruled that the jury found Ryan guilty of bribery giving three reasons. First, the jury was instructed that bribes are considered income under the Internal Revenue Code while gifts from friends are not. Based on this instruction, the jury still found that Ryan had received payments for official acts. Second, the court found that the prosecution did not argue that the jury should convict Ryan because he failed to disclose benefits received Lawrence Warner who provided Ryan and his family with extensive benefits which was disapproved in the Wood v. Milyard [SCOTUS blog backgrounder; JURIST report]. The court in