A federal appeals court has reinstated the conviction of Autumn Jackson, who was freed in June while serving time for trying to extort $40 million from Bill Cosby. (Jackson, 25, was sentenced in 1997 to two years and two months in prison after she was convicted of extortion, conspiracy and crossing state lines to commit a crime.) The 2nd U.S. Circuit Court of Appeals in New York ruled Monday that improper jury instruction was not sufficient to overturn her conviction. The ruling, made by the same panel which freed Jackson, may lead to her return to prison for another seven months. Defense attorney Robert Baum said his client "was devastated by the news."