On October 29th, the Seventh Circuit upheld Conrad Black's convictions on one count of obstruction of justice and one count of pecuniary fraud. On remand after the Supreme Court held that the trial court's jury instructions on honest services fraud were incorrect, the Seventh Circuit found that it is not open to reasonable doubt that the jury would still have convicted Black on the obstruction of justice charge and one count of pecuniary fraud. The Seventh Circuit reversed the convictions on two other pecuniary fraud counts as tainted by the improper honest services fraud jury instructions and remanded for retrial on those counts and resentencing. U.S. v. Black.