United States v. Dean A. Tran — 1st Cir. (Oct 6, 2026)

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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…