The 7th U.S. Circuit Court of Appeals rejected former Governor of Illinois and convicted felon (not that one) George Ryan's collateral attack on his conviction for honest-services fraud in light of Skilling. The court reasoned that Ryan's arguments were far afield from those adopted in Skilling and concluded: "There is no doubt that a properly instructed jury could have deemed the payments bribes or kickbacks; the inference that they were verges on the inescapable."