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Not all bribery falls under the FCPA

Department of Justice
U.S. Attorney’s Office
Eastern District of Arkansas

Thursday, October 27, 2016

Owner of Arkansas Juvenile Mental Health Facilities Sentenced to 84 Months in Prions for Bribery Scheme


WASHINGTON – The owner of two Arkansas mental health companies that provide inpatient and outpatient mental health services to juveniles was sentenced to serve 84 months in prison today for engaging in a scheme to bribe a former deputy director of the Arkansas Department of Human Services (ADHS), announced Assistant Attorney General Leslie R. Caldwell of the Department of Justice’s Criminal Division.

Theodore E. Suhl, 50, of Warm Springs, Arkansas, was previously convicted of two counts of honest services fraud, one count of federal funds bribery and one count of interstate travel in aid of bribery. In addition to his prison sentence, Suhl was ordered to pay a $200,000 fine.

The evidence presented at trial showed that Suhl bribed former deputy director of ADHS, Steven B. Jones, using intermediaries Phillip W. Carter and a local pastor. Beginning in approximately April 2007, Suhl, Jones and Carter periodically met at restaurants in Memphis, Tennessee, or in rural Arkansas in order for Suhl to request assistance for his companies from Jones in his capacity as deputy director of ADHS. Jones agreed to perform official acts that benefitted Suhl and Suhl’s businesses and provided internal ADHS information to Suhl. In exchange for Jones’s agreement to perform official acts, Suhl paid Jones by funneling cash payments through the pastor’s church and providing the bribe payments to Jones in cash so that the transactions would not be easily traceable. Putting Jones on Suhl’s illicit payroll paved the way for more than $1.5 million in profits for Suhl’s juvenile mental health counseling business.

Jones pleaded guilty to federal funds bribery and conspiracy for his involvement in the scheme and was sentenced to 30 months in prison. Carter pleaded guilty to conspiracy to commit federal funds bribery and honest services wire fraud and was sentenced to 24 months in prison.

The FBI’s Little Rock Field Office investigated the case. Trial Attorneys John D. Keller, Lauren Bell and Amanda R. Vaughn of the Criminal Division’s Public Integrity Section prosecuted the case.


DOJ News Release

Categories: Anti-Corruption Department of Justice (DOJ) Updates Enforcement Actions


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