Michael Avenatti Loses Appeal From Nike Extortion Convictions

Disgraced lawyer Michael Avenatti lost an appeal to undo his convictions for trying to extort millions of dollars from Nike Inc., after the Second Circuit rejected claims of insufficient evidence.

Avenatti argued that prosecutors failed to prove the “wrongfulness” element of his extortion crimes, as well as the intent and bribery elements of honest-services fraud. But the court found enough evidence to support the jury’s verdict, the appeals court said.

When dealing with a reputational threat, the wrongfulness element of extortion “requires consideration of both the demand made and the threat used to support it.” When each bears a ...