The U.S. Court of Appeals for the Second Circuit, again finding that jury instructions in public corruption trials after the U.S. Supreme Court’s McDonnell v. U.S. require greater clarity to sustain convictions, vacated the convictions of former New York state Senate Majority Leader Dean Skelos in a summary order issued Tuesday.

The ruling is the latest by the Manhattan appellate court to undo high-profile public corruption convictions won under former U.S. attorney Preet Bharara. Earlier this year, a panel similarly found former state Assembly speaker Sheldon Silver’s corruption conviction did not stand up under the new McDonnell scrutiny, as the panel found the intent of the jury couldn’t be deciphered given the instructions at trial.

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