November.23.2016
In a published decision on November 16, the Eleventh Circuit U.S. Court of Appeals rejected arguments challenging federal convictions for attempting to cause a financial institution to not file a required currency transaction report in violation of 31 U.S.C. Section 5324 (a) (1) and (d) (2). Addressing the defendant’s arguments in United States of America v. Johana Leon, the appeals court cited Orrick partner Courtney Linn’s 2010 article in the Santa Clara Law Review, Redefining the Bank Secrecy Act: Currency Reporting and the Crime of Structuring.
The reference to Courtney’s article can be found on page 4 of the decision. The Santa Clara Law Review article can be found here.
This is the second time in the past four months that Courtney, a white collar partner in our Sacramento office, has had an article cited in a published federal appeals court decision. The majority and dissenting opinions in a Fourth Circuit decision this past August both cited his article in the American Journal of Criminal Law, International Asset Forfeiture and the Constitution.