The court of appeals affirmed a judgment of the district court. The court held that prosecutors did not violate California Rule of Professional Conduct 2-100 by communicating through a cooperating confederate with a defendant charged with crimes of corruption and supplying the confederate with fake “subpoenas” for use in eliciting incriminating statements.
Michael Carona was the elected sheriff of Orange County, California from 1999 to 2008, when he resigned following an indictment on charges of corruption. In the course of the federal investigation leading to the indictment, Donald Haidl, a financial supporter of Carona, admitted to the government that he had engaged in criminal misconduct relating to Carona.
