171515P.pdf   06/29/2018  United States  v.  Kwame Askia
   U.S. Court of Appeals Case No:  17-1515
   U.S. District Court for the Western District of Arkansas - El Dorado   
   [PUBLISHED] Melloy, Author, with Gruender and Grasz, Circuit Judges] 
   Criminal case - Criminal law. 18 U.S.C. Sec. 666(a)(1)(A) is not a 
   continuing offense and a defendant may not be charged for a Section 
   666(a)(1)(A) offense committed outside the five-year statute of 
   limitations; however, as in this case, when a defendant has committed the 
   offense both within and outside the limitations period, he may be charged 
   with violations committed within the limitations period; the government 
   showed at least four of defendant's improper expenditures occurred within 
   the limitations period and totaled more than $5,000, the jurisdictional 
   amount; as defendant did not challenge the admission of evidence related 
   to expenditures outside the limitations period, the introduction of the 
   evidence is reviewed for plain error, and the court could not say that a 
   the supposed error in admitting the evidence seriously affected the 
   fairness, integrity or public reputation of the judicial proceedings; no 
   error in admitting a purported grant application into evidence; any error 
   concerning admission of hearsay at a pre-trial release proceeding was 
   moot; evidence was sufficient to support defendant's conviction.