In February 2019, a federal grand jury in Dallas, Texas indicted 63-year-old Ruel Hamilton, a real estate developer, on two counts of federal programs bribery relating to his dealings with two members of the Dallas City Council, Carolyn Davis and Dwaine Caraway.
He was accused of giving thousands of dollars to Davis between 2013 and 2015 for her support in his efforts to obtain low-income housing tax credits for one of his real estate projects. The tax credits were offered by the Texas Department of Housing and Community Affairs, a state agency. The City Council eventually had voted to recommend a slate of projects that included Hamilton’s project. Davis, who chaired the Dallas Housing Committee, had allegedly lobbied for Hamilton’s project. In the end, none of the tax credits were granted for any of the projects on the slate.
The indictment alleged that Hamilton funneled money to Davis in part by giving money to Hip Hop Government, a non-profit owned by Jeremy Scroggins, who was Davis’s campaign manager.
The indictment also alleged that in 2018, Hamilton was seeking to get a paid sick leave ordinance on the ballot in an upcoming election. After his attempt to get sufficient signatures to get the proposed ordinance on the ballot was unsuccessful, Hamilton’s only recourse was to get the City Council to vote to put the measure on the ballot. He was accused of paying $7,000 to Caraway on August 3, 2018, for Caraway’s influence on then-Mayor Mike Rawlings to put the initiative on the City Council agenda. Caraway did not ultimately speak to Mayor Rawlings regarding the initiative, and the initiative was not placed on the City Council agenda for consideration as a ballot item.
A week after Hamilton was indicted, Davis was charged with bribery and later pled guilty.
Five months later, on July 15, 2019, Davis and her 26-year-old daughter were killed when their car was hit by a drunk driver. On July 19, 2019, Scroggins pled guilty to a federal charge of misprision of a felony for failing to report the money he received from Hamilton.
In December 2019, the prosecution filed a superseding indictment against Hamilton. The two bribery counts were joined by a count of conspiring to violate the federal bribery statute. An additional count accused Hamilton of violating the federal Travel Act, which criminalizes the use of interstate facilities, such as the telephone, in furtherance of the bribery scene, based on Hamilton’s telephone call to Caraway.
In June 2021, Hamilton went to trial in U.S. District Court in Dallas. The prosecution’s case was based on recordings of calls between Davis and Hamilton, as well as testimony from Caraway and Scroggins.
According to Caraway, he missed a call from Hamilton because he was in the process of agreeing to plead guilty in federal court for taking about $500,000 in kickbacks and bribes in another case. When Caraway showed FBI agents the missed call, agents told him to call back to find out what he wanted. The call was recorded. In the call, Hamilton made a pitch about the paid leave ordinance. Caraway said he was having health problems and suggested they meet in person the next day, August 3, 2018. The meeting was secretly videotaped.
At the start of the meeting, Caraway called his mother on speaker phone and talked about her health problems. He said he would see her later that day to handle paperwork and “pay all that stuff today.” After the call, Caraway and Hamilton began talking about the paid sick leave ordinance and how a vote could come about if the mayor put the item on the Council agenda.
At one point, Hamilton said, “I don’t know for sure if you’re going to run again, [but] I hope you do.” He also said, “I think you’ve been doing an extraordinary job in your district. I want you here and I think that you and I can get a lot of stuff done. I really do.”
“Before you leave office or whenever your last term is, we’re going to have stuff built down there on Eleventh Street. You just watch. I need you for that,” Hamilton said. “What I’m saying is, I’m there, you know, and so if there is anything I can help you with, I mean, I hope you feel like you can reach out.”
Caraway then said, “I’m reaching out today…I got to go find me $6,200 today. Man, let me tell you something, trying to survive in this–in this and…not campaign at all, it’s, it’s difficult man.”
Caraway said his health was failing. When Hamilton circled back and asked how he could help, Caraway replied, “You can answer that bill that I just threw out there…[for about $6,200] today and that will help me…do what I need to do.”
Hamilton asked if he could just write a check to Caraway. Caraway said this was not a loan and that it had nothing to do with the campaign. He just had to “go pay for my mama.”
Hamilton wrote a check for $7,000.
Caraway, in his testimony, said he considered the payment a bribe for his influence supporting the paid leave ordinance.
Scroggins testified that some of the money given to Hip Hop Government was passed on to Davis personally. He said he cashed checks from Hamilton and gave the cash to Davis.
Hamilton’s counsel elicited testimony and presented evidence that Hamilton did not know what Davis and Scroggins did with his donations and maintained that his funding of Davis’s causes and candidates was above board. Hamilton’s counsel also argued that Hamilton gave the money to Caraway as a way of helping out a friend
Hamilton sought to introduce evidence that before Davis was killed in the crash, she had told others that she had pled guilty only out of fear and that she intended to seek to withdraw the plea. She had told friends that Hamilton “did not do anything wrong” and did not pay her any bribes. The prosecution’s objection to that testimony was sustained by the trial judge. The prosecution was also not permitted to present evidence that Davis had entered into a plea.
Over the objection of Hamilton’s defense lawyers, U.S. District Court Judge Barbara M.G. Lynn instructed the jury relating to the bribery counts that neither a quid pro quo exchange nor any “official act” by the council members was required. Judge Lynn said nothing about whether any of Hamilton’s activities were protected by the First Amendment. The judge also declined to give an additional instruction about entrapment relating to Hamilton’s phone call and meeting with Caraway.
On June 29, 2021, the jury convicted Hamilton on the two bribery counts and the conspiracy count. The jury acquitted him on the Travel Act count. Judge Lynn sentenced Hamilton to eight years in prison and fined him $150,000. Although he was given a date to surrender to prison, ultimately, he was allowed to remain free on bond to deal with health issues.
Attorneys Abbe Lowell, Christopher Man, Dion Robbins, and Kaitlin Pierce Marino from the law firm of Winston and Strawn and co-counsel Paul Clement appealed. They argued that the judge had been given erroneous jury instruction regarding the bribery charges and should have given the entrapment instruction.
On August 23, 2022, the Fifth Circuit U.S. Court of Appeals vacated all of Hamilton’s convictions and ordered a new trial.
“The district court believed that [the bribery statute] criminalized mere gratuities and did not require a quid pro quo,” the court ruled. “Our court has not yet had the opportunity to address this question. We conclude that [it] does, in fact, require a quo ; a quid alone will not suffice. And the jury instruction that the district court gave did not convey that.”
The court added, “The lack of such a quid pro quo instruction rendered the jury instructions unclear, as the jurors were permitted to convict on an illegal-gratuity theory that does not exist.”
The court also ruled that Hamilton was entitled to an entrapment instruction. “ Viewing the evidence in the light most favorable to Hamilton, we conclude that he made a prima facie showing (1) that he lacked the predisposition to bribe Caraway, and (2) that the government was involved in the operation beyond merely making the opportunity available to him,” the court ruled.
The prosecution petitioned for a rehearing, but the petition was denied in February 2023.
When the prosecution said it would retry the case, the defense argued that double jeopardy precluded a retrial on the Caraway bribery count. The defense noted that because the jury had acquitted him on the Travel Act count, which was tied to the Caraway bribery charge, it had found that the check was not a quid pro quo bribe. Judge Lynn denied the motion, ruling that the Travel Act count related to the phone call on August 2, 2018, while the bribery count related to the writing of the check the following day, August 3, 2018.
“[A] lack of the requisite specific intent for the alleged Travel Act violation on August 2 is not dispositive of whether Hamilton paid a bribe on August 3,” the judge ruled.
The defense appealed. On September 30, 2024, the Fifth Circuit upheld the lower court ruling.
In June 2025, Hamilton went to trial again, represented by Abbe Lowell (now of Lowell & Associates), and Tom Melsheimer, Damien Diggs, Alex Wolens, Kaitlin Pierce Marino, and Emily Wilkinson of Winston & Strawn. The prosecution’s case remained the same, except for Caraway’s testimony. By this time, Caraway had completed his sentence. His original sentence of 56 months had been reduced to 51 months after he testified in the 2021 trial.
During the retrial, Caraway told the jury that he did not consider Hamilton’s payment a bribe, recanting his testimony at Hamilton’s first trial. He testified that he and Hamilton were friends, and that people in Caraway’s community knew he was having challenges with his own health and his mother’s health. He testified that he shared personal details with Hamilton during that meeting because he wanted to encourage Hamilton to write him a check to cover those expenses. He testified that after the August 3 meeting, Hamilton never called him to “follow up” on whether Caraway ever called the Mayor regarding the initiative, and that the initiative was never placed on the City Council agenda. He also testified that the FBI agents gave Caraway the impression they wanted Caraway to have the recorded in-person meeting with Hamilton on August 3, and not just have a phone call on August 2. He described how the FBI agents, who were waiting nearby during his meeting with Hamilton, reacted with happiness when Caraway arrived at the hotel room with the $7,000 check.
Scroggins admitted during his testimony that he had never met with Hamilton.
The defense presented evidence and elicited testimony that none of the money that Hamilton gave to Davis, Hip Hop Government, or Caraway was given in exchange for any official action.
Melsheimer and Wolens argued that the money to Carraway was to help with Carraway’s mother’s medical expenses and that the money that went to Davis and Hip Hop Government were consulting fees.
On June 12, 2025, the jury, after receiving the jury instructions regarding entrapment and that a quid pro quo exchange was required, acquitted Hamilton on all counts.
Afterward, Hamilton issued a statement: “ I believed in the system and the fairness of our jury. My family and I are grateful to our family, friends and lawyers who stuck with us to the end.”
– Maurice Possley
Posting Date: 06-23-2025
