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7th Circuit Affirms Conviction of Harvey Building Inspector in Travel Act Case

The U.S. Court of Appeals for the Seventh Circuit affirmed the conviction of former Harvey, Illinois building inspector Lester Crowder under the federal Travel Act for using interstate facilities to promote bribery. The court rejected Crowder's arguments challenging jury instructions, evidence sufficiency, and the constitutionality of Illinois bribery statutes.

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Seal of the Seventh Circuit Court of Appeals

Case Information

Case No.:
No. 24-2143
Judges:
Pryor

Key Takeaways

  • Former Harvey building inspector Lester Crowder convicted under Travel Act for bribery scheme
  • Seventh Circuit rejected appeals challenging jury instructions, evidence sufficiency, and constitutional arguments
  • Case involved FBI investigation using confidential informant who recorded meetings with Crowder
  • Conviction demonstrates federal reach into local corruption through interstate commerce nexus

The U.S. Court of Appeals for the Seventh Circuit affirmed the conviction of Lester Crowder, a former Harvey, Illinois building inspector, under the federal Travel Act for his role in a bribery scheme involving a proposed strip club. The three-judge panel unanimously rejected Crowder's appeals challenging jury instructions, evidence sufficiency, and constitutional arguments in the case decided Jan. 22.

Crowder was convicted under 18 U.S.C. § 1952, commonly known as the Travel Act, which criminalizes the use of interstate facilities to promote unlawful activity. The statute requires prosecutors to prove defendants used interstate commerce to further illegal enterprises, in this case bribery in violation of Illinois law.

The case originated from an FBI investigation involving Dennis DeZutter, general manager of a strip club in Harvey who served as a confidential informant. In January 2018, DeZutter expressed interest to Rommell Kellogg about opening a new strip club in the city. Kellogg, brother of Harvey Mayor Eric Kellogg, told DeZutter he could "make that happen" and introduced him to Crowder.

Crowder had previously worked as a building inspector for Harvey but left city employment in January 2014, four years before the alleged bribery scheme. Despite no longer holding an official position, Crowder apparently maintained connections within the city government through his longstanding relationships with the mayor and his family members, having grown up alongside Eric Kellogg and his two brothers, Derrick Muhammad and Rommell Kellogg.

Between February and April 2018, DeZutter and Crowder met nine times to discuss the proposed strip club project. Their initial meeting occurred Feb. 13, 2018, at a potential site for the new establishment. The men continued meeting through the end of April 2018, arranging their encounters through text messages and phone calls.

Working with federal investigators, DeZutter recorded video and audio of each meeting with Crowder, as well as their phone calls and text message exchanges. These recordings formed the foundation of the government's case against Crowder, providing direct evidence of the alleged bribery scheme.

The government argued that Crowder used interstate facilities - specifically electronic communications crossing state lines - to advance the bribery plot in violation of Illinois law. Federal prosecutors successfully convinced a jury that Crowder's actions fell within the scope of the Travel Act's prohibition on using interstate commerce to promote illegal activity.

On appeal, Crowder raised three primary arguments challenging his conviction. First, he contended the district court committed reversible error by omitting an essential element of the offense in its jury instructions. Second, he argued the government failed to present sufficient evidence to support his conviction. Third, Crowder challenged the constitutionality of the Illinois bribery statute under which his Travel Act conviction was based.

The Seventh Circuit panel, consisting of Circuit Judges Sykes, Jackson-Akiwumi, and Pryor, found none of Crowder's arguments persuasive. Writing for the court, Circuit Judge Pryor concluded that Crowder's challenges "do not warrant reversal" and affirmed the lower court's judgment.

The decision represents the latest development in ongoing federal investigations into corruption within Harvey's city government. The case highlights how federal prosecutors can use the Travel Act to reach local corruption schemes that involve interstate elements, even when defendants no longer hold official positions.

The Travel Act has become an important tool for federal prosecutors pursuing corruption cases involving state and local officials. The statute allows federal jurisdiction over cases that might otherwise remain in state courts by establishing the interstate nexus required for federal prosecution.

Crowder's conviction demonstrates how modern communications technology can create the interstate commerce connection necessary for Travel Act prosecutions. Text messages, phone calls, and electronic communications that cross state boundaries can provide the federal hook prosecutors need to bring charges under the statute.

The case also illustrates the effectiveness of cooperating witnesses and electronic surveillance in corruption investigations. DeZutter's role as a confidential informant allowed federal agents to document the alleged bribery scheme in real time through recordings that provided compelling evidence for prosecution.

Harvey, located in Cook County south of Chicago, has faced ongoing scrutiny over municipal operations and governance issues. The successful prosecution of Crowder adds to federal efforts to address corruption in local government operations throughout the region.

The district court case was handled by Judge Martha M. Pacold in the Northern District of Illinois, Eastern Division. The appeal was argued before the Seventh Circuit on May 14, 2025, with the decision issued more than eight months later.

Crowder's conviction and the affirmance on appeal send a clear message about federal enforcement priorities regarding corruption in local government, even when defendants no longer hold official positions. The case demonstrates that personal relationships and informal influence can still subject individuals to federal prosecution under appropriate circumstances.

Topics

briberyTravel Act violationpublic corruptionmunicipal governmentFBI investigationappellate review

Original Source: courtlistener

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