The results were uneven. Fall and Doheny were acquitted of conspiracy to defraud the United States in December 1926. Sinclair was acquitted of conspiracy in April 1928. Fall was later convicted of receiving Doheny’s bribe; in March 1930 another jury acquitted Doheny of giving it. The Federal Judicial Center describes the public bewilderment at those outcomes.[1]
That is not a typo to be repaired by silently changing the acquittal into a conviction. Criminal cases must establish the charged defendant’s offense to the criminal standard, on the evidence admitted in that proceeding. Different charges, evidentiary rulings and fact-finders can produce outcomes that look difficult to reconcile. An acquittal is an important legal outcome; it does not require a finding that every disputed transaction was proper.
The civil cases answer another part of the story. In Mammoth Oil, the Supreme Court upheld cancellation on grounds including fraudulent collusion. It expressly said it did not need to decide whether Fall had been bribed. This means the government could recover the reserve without first winning a criminal bribery case against the oilman. Treating a civil recovery, a conspiracy acquittal and a bribery conviction as interchangeable loses the actual history.[2]
