Does a murder out of revenge or by a jilted lover constitute a murder-for-hire?

Thus, 1958 s pecuniary value requirement means that murder out of revenge or by a jilted lover does not constitute murder-for-hire. Nor does a defendants murder of his wifes ex-husband, in expectation that his wife would receive benefits from the ex-husbands life insurance, satisfy the requirement. See United States v. Wicklund , 114 F.3d 151, 15355 (10th Cir. 1997).

In United States v. Chong , we "specifically interpreted the language of 1958 s pecuniary value requirement," and held that "there must be evidence that the hitmen clearly understood they would receive something of pecuniary value in exchange for performing the solicited murderous act." 419 F.3d 1076, 1082 (9th Cir. 2005). In Chong , "the evidence show[ed] only that [the defendants co-conspirator] volunteered for a dangerous assignment and wound up getting some walking-around money in the course of traveling to Boston," where he then learned about the

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