In a significant ruling, the Seventh Circuit Court of Appeals upheld the 84-month prison sentence of Thomas E. Duncan, a former supervisor at the Department of Veterans Affairs (VA), who was involved in a scheme to defraud the agency. The court found no error in the district court's sentencing decisions, which included enhancements for multiple bribes and a substantial loss calculation. This ruling affects Duncan, who pleaded guilty to wire fraud, and serves as a warning against fraudulent activities within government agencies.
The case, officially titled United States v. Thomas Duncan, was filed under docket number 24-1822. The ruling, delivered on August 6, 2026, by Circuit Judge Jackson-Akiwumi, came after Duncan appealed the district court's decision, arguing that he should have received a lighter sentence. The court's decision is significant as it reinforces the legal consequences of corruption and fraud within public institutions.
Thomas Duncan worked as a supervisor at the Jesse Brown VA Medical Center in Chicago. Along with his co-defendant, Daniel Dingle, Duncan devised a fraudulent scheme that lasted over six years. They submitted fake orders for medical supplies, primarily blood pressure cuffs, from Dingle's medical supply company. The VA paid nearly $1.9 million for these non-existent supplies, while Duncan received kickbacks for facilitating the fraud. The scheme was discovered following an investigation, leading to Duncan's indictment on multiple counts of wire fraud.
After pleading guilty to one count of wire fraud, Duncan faced sentencing. The district court calculated a loss of over $1.7 million attributed to Duncan's actions and imposed enhancements based on the number of bribes involved. Duncan contested these enhancements, arguing that he was only responsible for a smaller portion of the loss and that the fraud involved a single bribe. However, the district court disagreed, stating that the fraudulent scheme involved multiple payments over time and that Duncan's actions warranted the enhancements applied.
The Seventh Circuit's ruling affirmed the district court's findings. The court stated, "Duncan’s fraud involved multiple bribes because Dingle made several payments to Duncan over many years and the scheme was 'ad hoc and intermittent.'" The court also supported the district court's loss calculation, noting that the evidence presented justified attributing a significant portion of the VA's losses to Duncan.
In its decision, the court emphasized that the district court's findings were not clearly erroneous. It stated, "The record demonstrates that the court found Duncan accepted multiple bribes based on the scheme’s duration, the co-defendants’ continued negotiations, and the absence of common indicia of a single bribe." This affirmation of the lower court's ruling highlights the seriousness of Duncan's actions and the legal system's commitment to holding public officials accountable for corruption.
The impact of this ruling extends beyond Duncan. It serves as a reminder of the legal ramifications associated with fraud and corruption within government agencies. The decision reinforces the importance of integrity in public service and the consequences of betraying that trust. It also sets a precedent for future cases involving similar fraudulent schemes, indicating that courts will take a firm stance against such misconduct.
Looking ahead, Duncan's options for appeal are limited. The Seventh Circuit's ruling is a final decision, and while there may be related cases involving other parties in the fraud scheme, Duncan's individual case appears to be concluded. The ruling underscores the legal system's commitment to addressing public corruption and ensuring that those who exploit their positions face significant consequences.