Source: cases/18usc1341/f3d-913-332-us-v-hird.case
Case source: https://www.neochart.com/catalog/cases/f3d/volume_913/0332_01/index.html
Under Pasquantino , then, traffic tickets (or more precisely, judgments arising from them) are considered an "entitlement to collect money from individuals, the possession of which is 'something of value.' "
We conclude that, as alleged, this scheme had the objective of preventing the City of Philadelphia and the Commonwealth of Pennsylvania from possessing a lawful entitlement to collect money in the form of fines and costs-a property interest-from individuals who Alfano and Hird assisted.
casedsl 1.2 # author: Flash3 (gemini-3.8-flash-high) # triaged-by: Fable (2026-11-10) case /f3d/913/0332-01 name United States v. Hird cite 913 F.3d 332 (2019) court United States Court of Appeals for the Third Circuit date 2019-01-18 url catalog/cases/f3d/volume_913/0332_01/index.html source ir/caselaw/f3d_913.jsonl sha1=01197d76f5e499152863efcc83fff3661afc7040 chars=60000 # single opinion (Nygaard, J.); its footnotes are appended from @55923 and belong to the same opinion. The IR text is capped at 60000 chars (later footnotes cut off). opinion op : majority by Nygaard @0..60000 controlling party p1 : William Hird (Traffic Court administrator) and Henry Alfano (private citizen) count c1 : mail fraud counts pleaded to (Alfano 51-56, Hird 58-60), Philadelphia Traffic Court ticket-fixing law 18usc1341 role applied posture criminal appeal after conditional guilty pleas to conspiracy, wire fraud and mail fraud; denial of Rule 12(b)(3)(B)(v) motion to dismiss the indictment (no "money or property" object) reviewed de novo on the indictment's allegations and affirmed. Co-appellants' perjury / false-statement convictions are not section 1341 matters. result claimant-won element property : satisfied [pleaded] party p1 count c1 route money-or-entitlement pattern ticket-fixing to obviate traffic-court judgments that would impose statutory fines and costs due to city and state fact @7543..7739 [supports] | In acceding to requests for "consideration," defendants were depriving the City of Philadelphia and the Commonwealth of Pennsylvania of money which would have been properly due as fines and costs. fact @15630..15853 [supports] | In contrast, the indictment here explicitly states that the scheme deprived the City and the Commonwealth of money, and it describes the object of the scheme as obviating judgments of guilt that imposed the fines and costs. fact @23884..24002 [supports] | The Motor Vehicle Code imposes fines and costs for each violation, eliminating any judicial discretion in this regard. fact @17883..17972 [cuts-against] | None of the cases directly associated with Alfano and Hird resulted in a guilty judgment. rule @22728..22935 | Under Pasquantino , then, traffic tickets (or more precisely, judgments arising from them) are considered an "entitlement to collect money from individuals, the possession of which is 'something of value.' " held @24109..24396 | We conclude that, as alleged, this scheme had the objective of preventing the City of Philadelphia and the Commonwealth of Pennsylvania from possessing a lawful entitlement to collect money in the form of fines and costs-a property interest-from individuals who Alfano and Hird assisted. gloss Fines and costs imposed by judicial judgment are money legally due (Pasquantino), not a purely regulatory interest (Cleveland distinguished); the absence of any guilty judgment is no answer because the scheme's object was to prevent such judgments. Facts are the indictment's allegations, taken as true. misfit The only section 1341 question reserved by the plea agreements was the property object; deception / scheme, intent, mailing and furtherance were not contested and are not recorded.