July 22, 1992 ____________________
July 22, 1992 ____________________

No. 90-2180
No. 90-2180

UNITED STATES OF AMERICA,
UNITED STATES OF AMERICA,

Appellee,
Appellee,

v.
v.

GEORGE M. BUCUVALAS,
GEORGE M. BUCUVALAS,

Defendant, Appellant.
Defendant, Appellant.

_____________________
_____________________

No. 90-2181
No. 90-2181

UNITED STATES OF AMERICA,
UNITED STATES OF AMERICA,

Appellee,
Appellee,

v.
v.

ARISTEDES C. PORAVAS,
ARISTEDES C. PORAVAS,

Defendant, Appellant.
Defendant, Appellant.


_____________________
_____________________

No. 91-1018
No. 91-1018

UNITED STATES OF AMERICA,
UNITED STATES OF AMERICA,

Appellee,
Appellee,

v.
v.

ARTHUR L. VENIOS,
ARTHUR L. VENIOS,

Defendant, Appellant.
Defendant, Appellant.

_____________________
_____________________
























No. 91-2042
No. 91-2042

UNITED STATES OF AMERICA,
UNITED STATES OF AMERICA,

Appellee,
Appellee,

v.
v.

BEL-ART REALTY, INC.,
BEL-ART REALTY, INC.,

Defendant, Appellant.
Defendant, Appellant.

____________________
____________________


APPEALS FROM THE UNITED STATES DISTRICT COURT
APPEALS FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MASSACHUSETTS
FOR THE DISTRICT OF MASSACHUSETTS

[Hon. Douglas P. Woodlock, U.S. District Judge]
[Hon. Douglas P. Woodlock, U.S. District Judge]
___________________

____________________
____________________

Before
Before

Cyr, Circuit Judge,
Cyr, Circuit Judge,
_____________

and Coffin and Campbell,
and Coffin and Campbell,

Senior Circuit Judges.
Senior Circuit Judges.
_____________________

____________________
____________________



Morris M. Goldings with whom David R. Kerrigan, Mahoney, Hawkes &
Morris M. Goldings with whom David R. Kerrigan, Mahoney, Hawkes &
__________________ __________________ _________________
Goldings, Terry Philip Segal, Segal & Feinberg, and Kevin O'Dea were
Goldings, Terry Philip Segal, Segal & Feinberg, and Kevin O'Dea were
________ __________________ ________________ ____________
on brief for appellants.
on brief for appellants.
Carole S. Schwartz, Special Assistant United States Attorney,
Carole S. Schwartz, Special Assistant United States Attorney,
____________________
with whom Wayne A. Budd, United States Attorney, and Stephen P.
with whom Wayne A. Budd, United States Attorney, and Stephen P.
_______________ ___________
Heymann, Assistant United States Attorney, were on brief for appel-
Heymann, Assistant United States Attorney, were on brief for appel-
_______
lee.
lee.


____________________
____________________


____________________
____________________


2
2

















CYR, Circuit Judge. Defendants George M. Bucuvalas, Aristides C.
CYR, Circuit Judge.
_____________

Poravas, and Bel-Art Realty, Inc., appeal their convictions on two

counts of engaging, and conspiring to engage, in a pattern of racke-

teering activity, 18 U.S.C. 1962(c)-(d), multiple counts of mail

fraud, 18 U.S.C. 1341 and 2, and one count of conspiring to commit

mail fraud, 18 U.S.C. 371. Arthur L. Venios appeals his convictions

for mail fraud and conspiracy to commit mail fraud. We affirm the

convictions.



I
I

BACKGROUND
BACKGROUND
__________


From 1980 to 1987, Bucuvalas, Poravas, and Venios [hereinafter

"defendants"] owned and operated a number of nightclubs, peep shows,

movie theaters, and adult bookstores in Boston's Combat Zone (adult

entertainment district), which were managed from offices owned by

defendant Bel-Art Realty, Inc. [hereinafter "Bel-Art"] at 671 Washing-

ton Street. In order to be allowed to operate many of these estab-

lishments, it was necessary to obtain alcoholic beverage licenses, see
___

Mass. Gen. L. ch. 138, 1-78 (1991), and entertainment licenses, see
___

Mass. Gen. L. ch. 140, 181-185G, from municipal licensing boards to

which the applicants were obligated to disclose the identity and

background of all owners and managers of the premises to be licensed.1

____________________

1Chapter 138, section 15A, requires applicants to include "a sworn
statement . . . giving the names and addresses of all persons who have
a direct or indirect beneficial interest in said license." The

3
3

















In an attempt to conceal their prior criminal records, as well as

their interests in the various enterprises, defendants paid "straw"

persons and created sham corporations to "front" as record owners and

operators and, through the use of the United States mails, utilized

the names of these straw owners on license applications submitted to

the municipal licensing boards. Bel-Art, which was controlled by one

of defendants' coconspirators, aided the fraudulent scheme by execut-

ing several mock real estate "leases" to the straw owners. Unaware of

these misrepresentations, the municipal boards issued licenses to the

ostensibly independent and legitimate business establishments, and

subsequently renewed their licenses on an annual basis. The scheme

served a secondary purpose as well. When the municipality would

threaten to revoke a license for violation of its conditions, or the

Commonwealth of Massachusetts would attempt to collect back taxes,

defendants merely arranged a sham sale of the establishment to a new

straw owner. For good measure, between 1980 and 1986 Bucuvalas and

his coconspirators bribed licensing board members and police officers

to avoid accountability for infractions which might otherwise have

resulted in license suspensions or revocations.



____________________

chairman of the alcoholic beverage licensing board testified that the
board also "require[d] a criminal record affidavit to be filed."
Chapter 140, section 181, authorizes the Mayor's Office of Consumer
Affairs and Licensing to obtain all "reasonable information concerning
the conditions of the premises and actions to be taken to prevent
danger to the public safety, health, or order." The commissioner
testified that applicants were expected to complete "criminal record
information forms" on all principals of the licensed premises.

4
4

















In February 1989, the defendants were indicted on two RICO counts

and multiple counts of mail fraud2 and conspiracy to commit mail

fraud. The RICO counts alleged nine predicate acts of mail fraud and

six acts of bribery. The government sought criminal forfeiture of

several parcels of Bel-Art's real property which allegedly "afforded

the defendant . . . a source of influence over the [RICO] Enterprise."

See 18 U.S.C. 1963(a)(2). Following a fourteen-day trial, the jury
___

returned guilty verdicts on all counts against all defendants, as well

as an in personam criminal forfeiture verdict against certain Bel-Art
__ ________

properties.



II
II

DISCUSSION
DISCUSSION
__________


A. Motion to Suppress
A. Motion to Suppress
__________________

On September 25, 1987, FBI Special Agent Robert Jordan obtained a

warrant to search Bel-Art's second-floor offices at 671 Washington

Street, the reputed headquarters of the individual defendants' illegal

enterprise. The search warrant authorized seizure of "records,

____________________

2The mail fraud counts charged that the fraudulent scheme had two
purposes:

a .
defrauding the City of Boston in order to obtain money and
property by means of false and fraudulent pretenses, repre-
sentations and promises; and

b .
defrauding the United States and the Commonwealth of
Massachusetts of taxes.

5
5

















documents, notes and physical objects evidencing [defendants'] owner-

ship or control" of various businesses. Bel-Art moved to suppress the

seized evidence on the grounds that the warrant was not supported by

probable cause and did not describe with sufficient particularity the

items to be seized. See U.S. Const. amend. IV. The district court
___

denied the motion.


1. Probable Cause
1. Probable Cause
______________

Bel-Art contends that the affidavit accompanying the search

warrant application did not establish probable cause to believe that

documentary evidence of the alleged fraudulent scheme would be found

at the search premises. Bel-Art characterizes most of the information

in the affidavit as "stale," insofar as it related to events (the

employment of straw owners and the bribery of board members and police

officers by defendants or their coconspirators) which took place

between 1960 and 1983, none less than four years prior to the search

warrant application.3

The probable cause determination is to be upheld if, "given all

the circumstances set forth in the affidavit . . ., including the

'veracity' and 'basis of knowledge' of persons supplying hearsay

____________________

3Bel-Art challenges the affidavit on the ground that neither the
affiant, Special Agent Jordan, nor his sources, directly observed any
incriminating evidence at the Bel-Art premises prior to the warrant
application. However, since circumstantial evidence alone may estab-
lish probable cause, the affidavit would not have been rendered
fatally defective for this reason alone. See United States v. Rahn,
___ _____________ ____
511 F.2d 290, 293 (10th Cir.) (lack of direct observation of weapon
not fatal to "probable cause" showing where "individuals [normally]
keep weapons in their homes."), cert. denied, 423 U.S. 825 (1975).
____ ______

6
6

















information, there is a fair probability that contraband or evidence
____ ___________

of a crime will be found in a particular place." Illinois v. Gates,
________ _____

462 U.S. 213, 238 (1983) (emphasis added); see United States v. White,
___ _____________ _____

766 F.2d 22, 25 (1st Cir. 1985); Rahn, 511 F.2d at 293 (affidavit need
____

not demonstrate "certainty" that items will be found). Moreover, the

supporting affidavit must be viewed in a practical, "common sense"

fashion, and we accord considerable deference to reasonable inferences

the judicial officer may have drawn from the attested facts. See
___

United States v. Falon, 959 F. 2d 1143, 1147 (1st Cir. 1992) (citing
_____________ _____

United States v. Ventresca, 380 U.S. 102, 108 (1965)); United States
_____________ _________ _____________

v. Tabares, 951 F.2d 405, 408 (1st Cir. 1991).
_______

Staleness does not undermine the probable cause determination if

the affidavit contains information that updates, substantiates, or

corroborates the stale material. See Emery v. Holmes, 824 F.2d 143,
___ _____ ______

149 (1st Cir. 1987); United States v. Ciampa, 793 F.2d 19, 24 (1st
______________ ______

Cir. 1986); United States v. Moscatiello, 771 F.2d 589, 597 (1st Cir.
_____________ ___________

1985); United States v. Viegas, 639 F.2d 42 (1st Cir.), cert. denied,
_____________ ______ ____ ______

451 U.S. 970 (1981). Moreover, whether "averments in an affidavit are

sufficiently timely to establish probable cause depends on the partic-

ular circumstances of the case." United States v. Hershenow, 680 F.2d
_____________ _________

847, 853 (1st Cir. 1982); see also United States v. Di Muro, 540 F.2d
___ ____ _____________ ________

503, 516 (1st Cir. 1976), cert. denied, 429 U.S. 1038 (1977), and
____ ______

cert. denied, 429 U.S. 1038 (1977). Staleness is not measured merely
____ ______

on the basis of the maturity of the information but in relation to (1)

the nature of the suspected criminal activity (discrete crime or

7
7

















"regenerating conspiracy"), (2) the habits of the suspected criminal

("nomadic" or "entrenched"), (3) the character of the items to be

seized ("perishable" or "of enduring utility"), and (4) the nature and

function of the premises to be searched ("mere criminal forum" or

"secure operational base"). Moscatiello, 771 F.2d at 597 (quoting
___________

Andresen v. State, 331 A.2d 78 (Md. App. 1975)), aff'd, 427 U.S. 463
________ _____ _____

(1976)); see also Rivera v. United States, 928 F.2d 592, 602 (2d Cir.
___ ____ ______ _____________

1991); Rahn, 511 F.2d at 293. The evidence detailed in Agent Jordan's
____

supporting affidavit defines an "entrenched," "regenerating" criminal

conspiracy which was sustained and perpetuated through an extensive

web of fraudulent license applications, renewals, "straw" ownerships,

and a pattern of bribes extending over a period of at least seven

years. Although most events described in the affidavit occurred

before 1983, a reliable informant reported that he saw one of the

defendants' coconspirators bribe a Boston police officer as recently

as August 1987, just one month before the search warrant. In addi-

tion, through licensing board records Agent Jordan verified that a

person identified to an informant in 1980 as a straw owner was still

designated a record owner on license renewal applications filed in

behalf of one of the defendants' business establishments as late as

1986.

The affidavit presented enough circumstantial evidence from which

a judicial officer reasonably could have inferred that documentary and

physical evidence of the alleged ongoing conspiracy would be located

in the second-floor Bel-Art offices at the time of the search. From

8
8

















1980 through September 1987, the suite of offices at 671 Washington

Street served as the apparent hub of directive activity for defend-

ants' illegal enterprise and the central repository for important

records relating to the ownership and operation of their various

businesses.4 It would be reasonable to infer that licensing informa-

tion, documentary evidence, and important records relating to the

ownership and operational control of an enterprise conducted at

numerous, dispersed locations probably would be kept at some secure,

centralized location, especially records of "enduring utility." The

likelihood that Bel-Art's second-floor office suite at 671 Washington

Street was the central repository for the business records of the

criminal enterprise was corroborated on September 18, 1987, just days

before the search warrant issued, when police officers conducted a

license inspection at one of defendants' establishments, observed an

illegal amusement device, and asked the manager to produce a license.

The manager referred the inspecting officers to the second-floor

offices at 671 Washington Street, where the officers observed defen-

dant Poravas placing papers in one of four filing cabinets. While on

the premises, the officers noticed video monitors which afforded the

____________________

4We recite some of the information in the affidavit. The offices were
the site of meetings in 1981, at which were discussed plans for
bribing licensing board members. A coconspirator's employee reported
that, as of 1982, the daily income and receipts generated at defend-
ants' various establishments were routinely delivered to these offic-
es. In January 1987, another employee told a police officer that
entertainment licenses were kept at these second-floor offices.
Shortly after delivering a notice of a licensing board hearing to
defendant Poravas on September 12, 1987, a police officer saw Poravas
enter the second-floor offices.

9
9

















occupants of the second-floor offices a clear view of the entrance to

the office suite at all times, indicating the likelihood of a "secure

operational base."

We think the net "common sense" import of the information pre-

sented in the search warrant affidavit was sufficient to establish a

"fair probability" that the premises at 671 Washington Street were a

"secure operational base" and the centralized repository for the

records of the suspected criminal enterprise.


2. Particularity of Search Warrant
2. Particularity of Search Warrant
_______________________________

Bel-Art contends that the breadth of the search warrant descrip-

tion of the evidence to be seized left too much to the discretion of

the search party, inviting the sort of "general rummaging" for evi-

dence forbidden by the Fourth Amendment. See United States v. Abrams,
___ _____________ ______

615 F.2d 541, 543 (1st Cir. 1980).5 Ignoring the transitional phrase

____________________

5The evidence was described as follows:

[R]ecords, documents, notes and physical objects which con-
stitute evidence of and instrumentalities of violations of 18
U.S.C. 1961(c) and (d) (i.e., conducting and participating
in the affairs of an enterprise, and agreeing to do so,
through a pattern of racketeering activity consisting of
multiple acts of bribery and mail fraud), Title 18, U.S.C.
1341, and Title 18 U.S.C. 371, and, in particular, re-
___ __ __________
cords, documents, notes and physical objects evidencing the
ownership or control of businesses in the Combat Zone in
Boston, as described in 10 of the Affidavit of Special
Agent Robert J. Jordan, which are licensed by the Boston
Licensing Board and/or the Mayor's Office of Consumer Affairs
and Licensing Division . . . and the payment of bribes to
public officials with regulatory authority over such licensed
premises; said records, documents, notes and physical objects
to include licenses or copies thereof, personnel records and
payroll records, a list of employees, checkbooks and check

10
10

















("and, in particular") between the first and second clauses of the

warrant description, Bel-Art asks us to read the first clause (identi-

fying the suspected criminal offenses) independently of the particu-

larized list of items which follows. Accordingly, Bel-Art contends

that the first clause authorized the searching officers to engage in a

generalized rummaging for any item discovered on the search premises,

whether or not of the type particularly described in the second

clause. We do not agree.

The warrant authorized a search for the types of documentary

evidence particularly described in the second clause of the warrant,

the first clause serving the broader, yet defining, purpose of identi-

fying the criminal offenses the target evidence was expected to

establish.6 Thus, but for the search constraints in the second

clause we might agree that the particularity requirement of the Fourth

Amendment would not have been met. In light of the specific types of

____________________

stubs, accounting books and ledgers, invoices, corporate
books and records, including stock ledgers, documents bearing
the names and/or telephone numbers of police officers or
other municipal officials, citations, incident reports,
correspondence, and supplies and objects used in the opera-
tion of the listed businesses, including peep show tokens and
automatic amusement devices. (Emphasis added.)

6Bel-Art likewise challenges the last clause in the warrant descrip-
tion ("including peep show tokens and automatic amusement devices") on
the ground that "this general phrase is not sufficiently limited by
preceding language to evidence of a specific crime." By this argu-
ment, Bel-Art would have us ignore the first clause in the warrant
description, while contending elsewhere that the first clause con-
trolled the second to the point that it gave the executing officers
carte blanche authority to rummage. Of course, the scope of the last
_____ _______
clause in the warrant description is similarly informed by the first
and second clauses.

11
11

















items described in the second clause, however, the warrant met the

Fourth Amendment particularity requirement. Cf. Abrams, 615 F.2d at
___ ______

547 (general "tail" clauses will not negate earlier particularity in

main body of description) (citing Andresen v. Maryland, 427 U.S. 463
________ ________

(1976)). Unlike cases in which we have held that the breadth of the

search authorization exceeded the scope of the "probable cause"

showing, see, e.g., id. at 543 (warrant authorizing search for all
___ ____ ___

medical records overly broad where criminal conduct related to Medi-

care and Medicaid fraud); Application of Lafayette Academy, Inc., 610
______________________________________

F.2d 1, 3-4 (1st Cir. 1979) (authorization to search for all books and

papers held overly broad in FISLP-related fraud case), the second

clause of the description in the instant warrant tracked the allega-

tions of clandestine ownership for which probable cause was estab-

lished in the accompanying affidavit, see, e.g., Tabares, 951 F.2d at
___ ____ _______

408 (description of records of ownership and control sufficiently

particular), as well as the allegations of ongoing license infractions

at satellite establishments.7




____________________

7Bel-Art argues that the warrant description should have been limited
to documents prepared after 1980, the alleged date of the commencement
of the conspiracy. See Abrams, 615 F.2d at 543. However, we have
___ ______
never required such arbitrary limitations in warrant descriptions.
Id. ("[T]here is no limitation as to time and there is no description
___ __ ___
as to what specific records are to be seized.") (emphasis added); see
___
also Lafayette, 610 F.2d at 4 n.4 ("[E]fforts may also be required to
____ _________
narrow the documents by category, time periods, and the like.")
___ ___ ____
(emphasis added). Temporal delineations are but one method of tailor-
ing a warrant description to suit the scope of the probable cause
showing.

12
12

















B. Mail Fraud
B. Mail Fraud
__________

A general verdict which may have been based on an impermissible

alternative ground must be vacated. United States v. Kattar, 840 F.2d
_____________ ______

118, 123 (1st Cir. 1988) (citing Zant v. Stephens, 462 U.S. 359, 367-
____ ________

370 (1931)).8 Although the defendants could have been convicted of

mail fraud on the independent ground that they deprived the Common-

wealth of Massachusetts of tax revenues, they argue that McNally v.
_______

United States, 483 U.S. 350 (1987),9 precluded their convictions for
_____________

fraudulently depriving the City of Boston of its unissued liquor and
________

entertainment licenses, since the city held no cognizable "property"

interest in the unissued licenses.
________

McNally rejected the "intangible rights" theory as a basis for
_______

mail fraud prosecutions brought by the federal government against

corrupt state and local officials.10 The McNally defendants alleged-
_______

____________________

8The district court instructed the jury to decide whether the unissued
licenses were "property" in the hands of the city. We need not
consider whether the "property" issue determination was for the jury,
as defendants contend that McNally, as a matter of law, compels the
_______ __ _ ______ __ ___
conclusion that unissued licenses are not "property."

9Congress subsequently amended the mail fraud statute to nullify the
McNally rule. See 18 U.S.C. 1346 ("the term 'scheme or artifice to
_______ ___
defraud' includes a scheme or artifice to deprive another of the
intangible right of honest services."). The government does not
advocate retroactive application of the amended statute. See United
___ ______
States v. Bush, 888 F.2d 1145, 1145-46 (7th Cir. 1989) (ex post facto
______ ____ __ ____ _____
concerns bar retroactive application of 1346 to pre-1988 criminal
conduct).

10Section 1341 provides:

Whoever, having devised or intending to devise any scheme
or artifice to defraud, or for obtaining money or property by
means of false or fraudulent pretenses, representations, or

13
13

















ly used political office and influence, and their control over the

selection of insurers from which the State would obtain insurance

coverage, to funnel excess commission payments to insurance agencies

either owned or controlled by the defendants. Id. at 352-54. Since
___

comparably priced insurance coverage would have been required in any

event, the government neither contended that the alleged scheme

violated state law, id. at 361 n.9, nor that it resulted in ascertain-
___

able pecuniary loss to the State. Id. at 360. Rather, the prosecu-
___

tion depended entirely on the theory that defendants' breach of their

fiduciary duty as state officials defrauded citizens of their intangi-

ble right to honest state government. Id. at 354 n.4, 356.
___

In reversing defendants' convictions, the Supreme Court acknowl-

edged that section 1341 seemingly permitted conviction either for a
______

"scheme to defraud" or for a "scheme [to] obtain[] money or property
__

by means of false or fraudulent pretenses, representations, or promis-

____________________

promises, or to sell, dispose of, loan, exchange, alter, give
away, distribute, supply, or furnish or procure for unlawful
use any counterfeit or spurious coin, obligation, security,
or other article, or anything represented to be or intimated
or held out to be such counterfeit or spurious article, for
the purpose of executing such scheme or artifice or attempt-
ing so to do, places in any post office or authorized deposi-
tory for mail matter, any matter or thing whatever to be sent
or delivered by the Postal Service, or takes or receives
therefrom, any such matter or thing, or knowingly causes to
be delivered by mail according to the direction thereon, or
at the place at which it is directed to be delivered by the
person to whom it is addressed, any such matter or thing,
shall be fined not more than $1,000 or imprisoned not more
than five years, or both. If the violation affects a finan-
cial institution, such person shall be fined not more than
$1,000,000 or imprisoned not more than 30 years, or both.


14
14

















es." Id. at 358. The Court nevertheless rejected the government's
___

contention that the more general phrase "scheme to defraud"

permitted prosecutions for deprivation of the intangible right to

honest government involving no property loss to the defrauded party.

Consulting the "sparse" legislative history of section 1341, id. at
___

356-57, the Court held that the traditional meaning of the term

"defraud" is limited to a deprivation of property rights. Id. at 358-
___

59. Accordingly, where the government is the defrauded party, "any
__________

benefit which the Government derives from [section 1341] must be

limited to the Government's interests as property holder." Id. at
___

358-59 n.8.

McNally held that the intangible right to good government is not
_______ ___

"property," but offered no insight as to the types of interests which

might be deemed "property" in the hands of the government for purposes

of the mail fraud statute. Shortly thereafter, however, the Court

seemed to reaffirm the view that the term "property" is subject to

expansive interpretation. See Carpenter v. United States, 484 U.S. 19
___ _________ _____________

(1987); cf. United States v. Santa-Manzano, 842 F.2d 1, 3 (1st Cir.
___ _____________ _____________

1988) (a personal release might constitute property for purposes of

1341; "mail fraud statute's coverage 'is to be interpreted broadly

insofar as property rights are concerned.'") (quoting McNally, 483
_______

U.S. at 356).11 Carpenter was convicted of wire fraud, for divulg-

____________________

11Unlike McNally, Carpenter dealt with convictions under both the mail
_______ _________
fraud statute and the wire fraud statute, see 18 U.S.C. 1343. Given
___
their similar language, the Court held the McNally rationale applica-
_______
ble to both statutes. Carpenter, 484 U.S. at 25 n.6.
_________

15
15

















ing confidential information belonging to his employer, the Wall

Street Journal, in advance of scheduled publication dates. Carpenter,
_________

484 U.S. at 23. Carpenter held that, besides being deprived of its
_________

intangible right to "honest and faithful service," which McNally had
_______

held "too ethereal" an interest to come within the mail fraud statute,

the Journal had been deprived of "something of value." Id. at 25, 27.
___

The Court pointed out that notwithstanding its "intangible nature"

confidential business information traditionally has been treated under

state law as a "species of [intangible] property to which the corpora-

tion has the exclusive right and benefit." Id. at 26. Although the
___

Journal may have sustained no demonstrated monetary loss from the

premature disclosures,12 the Court decided that the newspaper had

"been deprived of its right to exclusive use of the information," an

"important aspect" of most property rights. Id. at 26-27.
___

The ramifications of McNally and Carpenter remain unclear. Some
_______ _________

courts of appeals have concluded that the government holds a "property

right" in unissued licenses and permits for purposes of the mail and

wire fraud statutes. See, e.g., Borre v. United States, 940 F.2d 215,
___ ____ _____ _____________

222 (7th Cir. 1991) (cable television franchise); Frank v. United
_____ ______

States, 914 F.2d 828, 833 (7th Cir. 1990) (surrendered driver's
______

license); United States v. Martinez, 905 F.2d 709, 715 (3d Cir.)
______________ ________

(medical license), cert. denied, 111 S. Ct. 591 (1990); see also
____ ______ ___ ____


____________________

12Presumably, the newspaper suffered no pecuniary loss as a result of
the premature disclosures since Carpenter did not supply the informa-
tion to Journal competitors, but directly to investors.

16
16

















United States v. Turoff, 701 F. Supp. 981, 991 (E.D.N.Y. 1988) (taxi-
_____________ ______

cab medallions); cf. United States v. Sacco, 923 F.2d 970, 973 (2d
___ _____________ _____

Cir.) (two members of three-judge panel express disagreement with

controlling circuit precedent that unissued waste dumpsite permit is

not "property"), reh'g granted on related grounds, 927 F.2d 726 (2d
_________________________________

Cir.), cert. denied, 111 S. Ct. 2018 (1991). Other courts of appeals
____ ______

have concluded that unissued licenses and permits are mere regulatory

manifestations of the police power which cannot be characterized as

property interests under McNally. See, e.g., United States v. Sch-
_______ ___ ____ ______________ ____

wartz, 924 F.2d 410, 418 (2d Cir. 1991) (arms export licenses); United
_____ ______

States v. Granberry, 908 F.2d 278, 281 (8th Cir. 1990) (school bus
______ _________

operating permits); United States v. Kato, 878 F.2d 267, 269 (9th Cir.
_____________ ____

1989) (FAA pilot licenses); Toulabi v. United States, 875 F.2d 122,
_______ _____________

126 (7th Cir. 1989) (taxi licenses); United States v. Dadanian, 856
_____________ ________

F.2d 1391, 1392 (9th Cir. 1988) (gambling license); United States v.
______________

Evans, 844 F.2d 36, 42 (2d Cir. 1988) (arms export permit); United
_____ ______

States v. Murphy, 836 F.2d 248, 254 (6th Cir.) (bingo permits), cert.
______ ______ ____

denied, 488 U.S. 924 (1988). Even though the issue is one of first
______

impression in this circuit,13 our analysis does not persuade us that

____________________

13Although McEvoy Travel Bureau, Inc. v. Heritage Travel, Inc., 904
___________________________ _____________________
F.2d 786, 791 (1st Cir.), cert. denied, 111 S. Ct. 536 (1990), sug-
____ ______
gested that the defendants' alleged scheme the obtaining of federal
agency approval to issue domestic and international airline tickets
did not deprive the government of "property," the "property" issue was
collateral to the disposition of the case. Appellant conceded the
issue on appeal, arguing instead that he had been defrauded by the
__
defendants' scheme, which resulted in the unilateral termination of
his exclusive contract with one of the defendants, the Norton Company.
McEvoy held that the complaint failed to allege a sufficient causal
______

17
17

















McNally precluded these convictions.
_______

First, the Court narrowly restricted the McNally holding to the
_______

intangible right to honest government. The Court specifically direct-
______ __________

ed its disapproval at a string of federal prosecutions which had

utilized section 1341 to prosecute corrupt state officials for abusing

their positions for purposes of self-dealing, even though the State

had refrained from criminalizing their conduct. But cf. Mass. Gen. L.
___ ___

ch. 138, 62 (violation of alcoholic beverage licensing statute

punishable by fine or imprisonment). Alluding to the rule of lenity

and to serious federalism concerns, the Court refused to "construe the
__________

statute in a manner that leaves its outer boundaries ambiguous and

involves the Federal Government in setting standards of disclosure and

good government for state and local officials." McNally, 483 U.S. at
_______

360. We think the Court's language counsels against extending McNally
_______

to cases in which the defendants are not government officials, the

core conduct has been criminalized under state law, and there are no

significant comity concerns about force-feeding federal ethical

standards to state and local governments.

In addition, given the Court's expansive interpretation of the

____________________

connection between defendants' racketeering activities and the injury
to plaintiff's business, since defendants' fraudulent application to
the federal agencies came one month after Norton terminated its
___ _____ _____
contract with McEvoy. Thus, whether the federal agencies were de-
frauded of their "property" was irrelevant to our conclusion that
McEvoy's complaint failed to state a civil RICO claim. See, e.g.,
___ ____
Arzuaga-Collazo v. Oriental Fed. Sav. Bank, 913 F.2d 5, 7 (1st Cir.
_______________ ________________________
1990) (RICO complaint insufficient to state "cause-in-fact" link, as
plaintiff's injury came before alleged predicate acts of bankruptcy
______
fraud).

18
18

















term "property" in Carpenter, and its consistent resort to state
_________ _____

common law and statutory law defining "property," we believe the

municipal government's interest in these alcoholic beverage and

entertainment licenses was in the nature of a "property" interest

within the meaning of McNally and Carpenter. In its broadest sense, a
_______ _________

"property" interest resides in the holder of any of the elements

comprising the "bundle of rights" essential to the use or disposition

of tangible property or to the exercise or alienation of an intangible

right. See, e.g., Brotherton v. Cleveland, 923 F.2d 477, 481 (6th
___ ____ __________ _________

Cir. 1991) ("The concept of 'property' in the law is extremely broad

and abstract. The legal definition of 'property' most often refers

not to a particular physical object, but rather to the . . . bundle of

rights recognized in that object . . . [including] the rights to

possess, to use, to exclude, to profit, and to dispose."). For

instance, in Carpenter the defendant held a possessory interest in the
_________

wrongfully-disclosed confidential information, while the Wall Street

Journal retained the right to control the manner of its use, dissemi-
_______

nation, and alienation. Similarly, the City of Boston had the right

to control the issuance of these licenses, in order to assure their

issuance to deserving licensees only.

Even if these licenses did not become "property" until their

issuance, see Konstantopoulos v. Town of Whately, 424 N.E.2d 210, 217
___ _______________ _______________

(Mass. 1981) (holder of entertainment license has protectable due

process interest), the city retained the right to control their

alienation by the licensees, a property right analogous to those

19
19

















recognized at common law (fee simple determinable with a possibility

of reverter). The licenses were renewable on an annual basis, and

defeasible on the occurrence of prescribed contingencies. Under Mass.

Gen. L. ch. 138, 23, "upon the expiration, suspension, revocation,

cancellation or forfeiture of such a license or permit [, the Common-

wealth] shall be entitled upon demand to the immediate possession

thereof." Furthermore, the issued licenses could not be transferred

to third parties without the prior approval of the appropriate licens-

ing board. See Mass. Gen. L. ch. 138, 15A; cf. Evans, 844 F.2d at
___ ___ _____

40 ("under some circumstances, the right to control the future alien-

ation and use of a thing is a property right."). Thus, at the very

least, defendants repeatedly deprived the City of Boston of its

reversionary interest in the fraudulently obtained licenses by renew-

ing and transferring the licenses in the names of straw owners.

Absent any of the serious federalism concerns involved in Mc-
___

Nally, we are disinclined to extend its sway where a defendant fraudu-
_____

lently deprives a local government of its right effectively to control

the issuance of local operating licenses and of its reversionary

interests in previously issued licenses.


C. Cruel and Unusual Punishment
C. Cruel and Unusual Punishment
____________________________

Bel-Art contends that the judgment of criminal forfeiture relat-

ing to property valued at approximately $2.3 million was so "grossly

disproportionate" to the seriousness of Bel-Art's criminal involvement

in the racketeering enterprise as to amount to "cruel and unusual


20
20

















punishment," or an "excessive fine," in violation of the Eighth

Amendment.14 See United States v. Busher, 817 F.2d 1409, 1415 (9th
___ _____________ ______

Cir. 1987) (prior to judgment of criminal forfeiture under RICO,

Eighth Amendment requires explicit proportionality findings). The

district court rejected Bel-Art's motion to delimit the criminal

forfeiture in monetary terms.

We bypass the unresolved question whether a corporation may

assert an Eighth Amendment claim. See Browning-Ferris Indus., Inc. v.
___ ____________________________

Kelco Disposal, Inc., 492 U.S. 257 n.22 (1989); United States v.
______________________ ______________

Pilgrim Market Corp., 944 F.2d 14, 22 (1st Cir. 1991); see also
_____________________ ___ ____

Johnson v. Robison, 415 U.S. 361, 366-67 (1974) (in construing stat-
_______ _______

ute, court shall avoid constitutional issues where possible). The

required threshold comparison between the gravity of Bel-Art's crimi-

nal conduct and the severity of the forfeiture penalty does not

support the "initial inference of gross disproportionality" needed for

a successful Eighth Amendment challenge. See Tart v. Commonwealth of
___ ____ _______________

Mass., 949 F.2d 490, 503 & n.16 (1st Cir. 1991).15 Without attempt-
_____

____________________

14The Eighth Amendment provides: "Excessive bail shall not be re-
quired nor excessive fines imposed, nor cruel and unusual punishment
inflicted." U.S. Const. amend. VIII.

15Bel-Art further contends that the defendants were selectively
prosecuted from among the many miscreants who defrauded the City of
Boston of licenses. Bel-Art relies on Busher, 817 F.2d 1409 (9th Cir.
______
1987), which was premised on the three-part test set out in Solem v.
_____
Helm, 463 U.S. 277, 290-92 (1983). In addition to a gross dispropor-
____
tionality determination, Solem would require a comparison of the
_____
forfeitures imposed for comparable offenses in Massachusetts and in
___
other jurisdictions. Recently, however, in a significant curtailment
of Solem, a majority of the Court favored either dispensing with the
_____
Solem test in all non-capital cases, or reaching Solem's inter- and
_____ _____

21
21

















ing to estimate the actual loss to its victims, Bel-Art bases its

entire disproportionality assessment on the bare contention that the

value of its forfeited property grossly exceeded the value of the

licenses and back taxes of which it deprived the City of Boston and

the Commonwealth of Massachusetts. See United States v. Pryba, 900
___ _____________ _____

F.2d 748, 757 (4th Cir.) ("Even if we thought a proportional analysis

was required, appellants have failed to proffer the information that

would be required for such an undertaking."), cert. denied, 111 S. Ct.
____ ______

305 (1990). The Busher court itself recognized that bald assertions
______

of this nature are insufficient, noting that such pecuniary discrepan-

cies naturally result from the congressional intendment that criminal

forfeitures under RICO are to serve punitive rather than compensatory
________

purposes. Busher, 817 F.2d at 1415.
______

Unlike forfeitures effected under section 1963(a)(1), which

target properties derived from the RICO enterprise, the Bel-Art
_______

forfeiture, relating to property "affording a source of influence over

a criminal enterprise," 18 U.S.C. 1963(a)(2)(D), would be warranted

only to the extent the jury determined the property to have been
__ ___ ______

tainted by the racketeering activity. See United States v. Angiulo,
___ _____________ _______

897 F.2d 1169, 1212 (1st Cir.) (explaining proportionality rule in

forfeiture proceedings), cert. denied 111 S. Ct. 130 (1990). The jury
____ ______

had ample evidence, none of which was challenged on appeal, from which

____________________

intra-jurisdictional analyses only "in the rare case in which the
____
threshold comparison of the crime committed and the sentence imposed
leads to an inference of gross disproportionality." Harmelin v.
________
Michigan, 111 S. Ct. 2680, 2707 (1991) (emphasis added).
________

22
22

















to infer that the forfeited Bel-Art properties were an indispensable

component of defendants' longstanding scheme to deprive the City of

Boston of licenses and the Commonwealth of Massachusetts of back

taxes. Moreover, the level of taint attaching to Bel-Art's property

necessarily depended largely on factual issues resolved adversely to

the defendants at their jury trial. Therefore, we conclude that Bel-

Art cannot succeed on the showing required to support the "initial

inference of gross disproportionality" needed for a successful Eighth

Amendment challenge.


D. Interest on Forfeiture Proceeds
D. Interest on Forfeiture Proceeds
_______________________________

Prior to its indictment, Bel-Art entered into a contract to sell

the real property which was subject to forfeiture. The government

obtained a pretrial order restraining the sale. Later, Bel-Art and

the government agreed to permit these properties to be sold pending

trial, and the sale proceeds ($3.1 million) were placed in interest-

bearing escrow accounts. The jury returned a proportional verdict of

forfeiture pursuant to section 1963(a)(2), and the bulk of the princi-

pal and accrued interest remaining in escrow was forfeited to the

United States.16 Bel-Art contends that the government is not entitled

to the accrued interest because (1) section 1963(a) fixes the amount


____________________

16Prior to the forfeiture verdict, the government released its claim
to one parcel of real property, and Bel-Art withdrew the sale proceeds
and the accrued interest attributable to the sale of the released
parcel. With the exception of the proceeds attributable to two
"untainted" apartment properties, the remaining principal and interest
in the escrow accounts ($2.3 million) was declared forfeit.

23
23

















of the forfeiture as of the commission of the criminal offense, and

(2) the government waived its right to the accrued interest.


1. Scope of Section 1963
1. Scope of Section 1963
_____________________

Section 1963(a)(2)(D) declares forfeitable "any property or

contractual right of any kind affording a source of influence over any

enterprise . . . in violation of section 1962." Bel-Art argues that

the interest on the escrowed funds is not forfeitable, as it accrued

on the lawfully invested sale proceeds. Where a criminal statute is

ambiguous, Bel-Art argues, the court should invoke the rule of lenity.

See United States v. Enmons, 410 U.S. 396, 411 (1973).
___ _____________ ______

Bel-Art's contention is foreclosed by section 1963(c), which

provides that title to forfeitable property "vests in the United

States upon the commission of the act giving rise to forfeiture."17


____________________

17The cases relied on by Bel-Art do not aid its argument. For in-
stance, Bel-Art cites United States v. Regan, 699 F. Supp. 36, 38
______________ _____
(S.D.N.Y. 1988), for the proposition that "the penalty imposed by the
RICO statute on a defendant's untainted property [is] in the nature of
a fine that is fixed and final as of the time of the crime." (Empha-
_____ ___ _____
sis added). There is no indication that the post-offense "accretions"
discussed in Regan were in the nature of accrued interest. More
_____
importantly, the court propounded its view as to the "fixed" nature of
the RICO forfeiture penalty largely without explanation, cited neither
the language nor the legislative history of section 1963, and relied
on no caselaw. Bel-Art also cites United States v. Conner, 752 F.2d
_____________ ______
566, 576 (11th Cir.), cert. denied, 474 U.S. 821 (1985), for the
____ ______
proposition that a section 1963 forfeiture penalty is "a money judg-
ment against the defendant for the same amount of money which came
____ ______
into his hands illegally in violation of [the statute]." (Emphasis
added). Taken in context, however, the quoted language clearly
relates to the narrower question whether the government is under an
obligation to trace specific funds in order to determine where the
_____
defendant secreted the tainted monies. The Conner court was not
______
confronted with the accrued interest question presented here.

24
24

















Addressing the broader question whether the district court may impose

prejudgment interest on the value of forfeitable property retained by
___________

the defendant during the period between its wrongful acquisition and

the judgment of forfeiture, this court stated that

the RICO forfeiture statute does not expressly provide for
the imposition of interest. RICO's provisions, however, were
intended to be liberally construed to accomplish the stat-
_________ _________
ute's objectives. . . . The forfeiture provision, in par-
ticular, constitutes one of the crucial weapons in the RICO
arsenal and should be liberally construed to accomplish its
purpose of attacking the economic power of illegal enterpris-
es. . . .

. . . If interest had not been imposed, the defendants
effectively would have been allowed to pocket three years
worth of interest earned on a real estate investment that, in
large part, was acquired with the proceeds of an extortionate
loan.

Angiulo, 897 F.2d at 1216 (emphasis added) (citations omitted).
_______

Applying the Angiulo rationale in the instant context, it is obvious
_______

that interest could not have accrued but for the deposit of the

proceeds from the sale of the forfeitable properties. No less clear-

ly, title to the forfeitable properties "vest[ed] in the United States

upon the commission of the act giving rise to forfeiture," 18 U.S.C.

1963(c), and, absent an express agreement to the contrary, interest

earned on the sale proceeds belongs to the entity entitled to the

escrowed principal.18

____________________

18Bel-Art would distinguish Angiulo on the ground that it involved a
_______
forfeiture under 1963(a)(1), not 1963(a)(2), but cites no authori-
ty for the attempted distinction. Cf. Angiulo, 897 at 1210 (de-
___ _______
fendant's proposition, that 1963 treats (a)(1) forfeitures as in
__
personam actions and (a)(2) forfeitures as in rem actions, unsupported
________ __ ___
by authority). The unqualified language of the "relation back"
provision in 1963(c) intimates no such distinction.

25
25

















2. Escrow Agreement
2. Escrow Agreement
________________

Finally, Bel-Art argues that the government waived its "relation

back" rights.19 Our review of the written agreement authorizing the

sale discloses no waiver. In return for the government's agreement to

permit the pending sale, Bel-Art agreed that "the proceeds of the sale

. . . shall be treated as the property from which they were derived
_____ __ _______ __ ___ ________ ____ _____ ____ ____ _______

for all purposes under [section 1963]." (Emphasis added). Bel-Art's
___ ___ ________

waiver contention depends entirely on the premise that the agreement

is silent on the issue of accrued interest.20 Given the presumptive
______

rights of the United States under section 1963(c), as well as the

express terms of the agreement permitting the sale, Bel-Art's conten-

tion fails.

Affirmed.
Affirmed.
________



____________________

19Bel-Art relies on United States v. Kingsley, 851 F.2d 16, 21 (1st
_____________ ________
Cir. 1988) (defendant entitled to interest earned on assets previously
subject to forfeiture where government breached implied promise to
place funds in interest-bearing account). Kingsley is readily distin-
________
guishable. There the government was estopped from invoking its
"relation back" rights because it deliberately disregarded a court
order to invest forfeitable assets during the period prior to forfei-
ture and the defendant reasonably relied on the government's implied
representation in entering into a plea agreement. See id. There was
___ ___
no such representation by the government in the present case.

20For example, Bel-Art cites paragraph (e) of the agreement, which
provides for Bel-Art's transfer of the "proceeds of the sale," not the
proceeds plus interest, in the event the co-escrowee is unavailable
____ ________
following a verdict of forfeiture. Since we are required to interpret
the agreement as a whole, however, giving weight where possible to all
of its provisions, see Spartans Indus., Inc. v. John Pilling Shoe Co.,
___ _____________________ _____________________
385 F.2d 495, 499 (1st Cir. 1967), Bel-Art cannot avoid the purport of
the broad language of paragraph (c) ("proceeds of the sale . . . shall
be treated as the property from which they were derived . . . .").

26
26