⚖ Oral Arguments, with Context

We hear United States against Dean Tran in the First Circuit. After his term as a Massachusetts state senator ended, Tran collected pandemic unemployment benefits while working as a paid consultant. The case also involves consulting and rental income he failed to report on his federal tax returns. A jury convicted him of wire fraud and false-tax-return offenses, and he now appeals those convictions. Federal wire-fraud law requires use of interstate or international communications to carry out a scheme to defraud. The debate includes whether it was reasonably foreseeable that Tran's online submissions would cross state lines. Tran also challenges an extra instruction given after jurors asked what would happen if they could not agree on some counts. An Allen charge encourages jurors to keep deliberating without surrendering their honestly held views. Whether the defense properly raised its objection at trial can affect appellate review. Plain-error review addresses an error not properly raised at trial: it must be clear, affect substantial rights, and seriously harm the fairness, integrity or public reputation of judicial proceedings; relief remains discretionary. Michael Walsh represents Tran and will seek to overturn the convictions; Donald Lockhart will defend them for the United States.

United States v. Dean A. Tran (No. 25-1142) — U.S. Court of Appeals for the First Circuit, argued October 6, 2026.