Bridgegate Case: Civil Rights Counts Dismissed, Fraud Convictions Later Reversed

Update (October 2026): In 2020, the Supreme Court unanimously reversed the remaining wire fraud and federal-program fraud convictions. It held that because the scheme did not aim to get money or property, it was not federal fraud. Kelly v. United States, 590 U.S. 391 (2020). The post below describes the case as it stood in 2018.

In 2018, the Third Circuit threw out two civil rights counts against Bill Baroni and Bridget Anne Kelly in the "Bridgegate" case, a scandal that made national headlines. Baroni was deputy executive director of the Port Authority of New York and New Jersey. Kelly was a deputy chief of staff to New Jersey Governor Chris Christie.

The appeal raised a hard question: can government officials violate citizens' civil rights by restricting their interstate travel? The court found that no constitutional right to interstate travel free of this kind of government interference had ever been clearly defined. Because that right had not been defined, the defendants could not be charged with violating it. Their other convictions remained, and the two awaited resentencing.

What Happened

Bridgegate Scandal

In 2013, the mayor of Fort Lee, New Jersey, refused to endorse Governor Christie for reelection. To punish him, Kelly, Baroni, and Port Authority official David Wildstein cut the lanes reserved for Fort Lee's morning commuters at the George Washington Bridge from three to one. They called it a "traffic study."

The closures started on the first day of school. The result was four days of gridlock in Fort Lee for thousands of commuters. The closures also blocked major road access to hospitals and slowed first responders.

Christie denied knowing about the plan or having any involvement. Former officials in his administration then fought criminal charges over the incident for about five years.

Wildstein pleaded guilty and testified against Kelly and Baroni in exchange for a deal. He avoided prison and was sentenced to probation. At trial, emails from Kelly's personal account showed she approved the lane closures. Kelly said Christie knew of the plan in advance and tacitly approved it before she sent the email asking for the lanes to be shut. Baroni said he did not know the closures were political payback.

Before the Third Circuit's 2018 opinion, Baroni had been sentenced to 24 months in prison and Kelly to 18 months.

The Defense Arguments

Kelly and Baroni were convicted of wire fraud, fraud on a federally funded program, and conspiracy, along with the civil rights counts. Their lawyers argued that using fraud laws this way was "unprecedented" and "not legally sustainable."

They said the government lost little or no money, or so little that it could not be called misuse of public resources. They also said these were not proper corruption or fraud cases, because neither defendant used public funds for personal gain. The defendants said they did not benefit personally and were only carrying out what the governor wanted.

The defense argued that prosecutors were forcing a new criminal theory onto conduct that did not fit it. In their view, serious laws usually used against officials who pocket money were being stretched to cover political misconduct.

The Third Circuit rejected those arguments and upheld the fraud convictions. As of late 2018, Kelly and Baroni had not served any time while their appeals went forward, and they were waiting to be resentenced after the civil rights counts were dismissed. Their lawyers said they would appeal to the Supreme Court, and they did. As noted in the update above, the Supreme Court agreed with them in 2020.

How Dismissing a Charge Can Affect the Sentence

As this case shows, charges can be thrown out even after sentencing. When some counts are dismissed, the judge usually has to resentence on the counts that remain, and the new sentence may be lower.

If you or a loved one is facing a serious federal charge, political or not, pay close attention to every part of the case, including sentencing. Even after a conviction, there may be ways to win on appeal or reduce a sentence, but the deadlines are short. In a federal criminal case, the notice of appeal is generally due within 14 days after the judgment is entered. FRAP 4(b)(1)(A). It helps to get a criminal defense attorney involved as early as possible.

Facing a federal sentence? Book a consultation to talk it through with Brandon Sample.