McDonnell v. United States
McDonnell v. United States | |
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Holding | |
An "official act" within the federal bribery statutes does not include merely setting up a meeting, calling another public official, or hosting an event. | |
Court membership | |
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Case opinion | |
Majority | Roberts, joined by unanimous |
Laws applied | |
Hobbs Act, Honest services fraud |
McDonnell v. United States, 579 U.S. 550 (2016), was a
In light of the Court's findings, U.S. District Judge
Case background
At the trial in the United States District Court for the Eastern District of Virginia, prosecutors charged Robert F. McDonnell and his wife with quid pro quo. The jury found the McDonnells guilty of multiple counts of corruption. James R. Spencer presided over the initial trial.
The United States Court of Appeals for the Fourth Circuit unanimously affirmed the convictions of the McDonnells.
Opinion of the Court
Impact
Narrowed Definition of Bribery
The ruling narrowed the legal definition of public corruption and made it harder for prosecutors to prove that a political official engaged in bribery.[4][5] The term "official act" does not occur in the statutes charged in the case; rather, the parties to the trial had agreed that they would use the definition of that term given in the federal bribery statute 18 U.S.C. § 201(a)(3) in interpreting those statutes. Thus, by construing the term narrowly the Supreme Court narrowed the definition of bribery.[6]
According to Bloomberg News, the ruling "appears to have opened the floodgates for reversals of high-profile public corruption cases, including William Jefferson, a former Louisiana congressman. Former New York State Assembly Speaker Sheldon Silver; Dean Skelos, a former majority leader of the New York state senate; and Skelos’s son, Adam Skelos, have since had corruption convictions overturned on similar grounds."[5]
Legal Citations
The ruling in the Supreme Court case was cited by United States District Court for the District of New Jersey as potential grounds for dismissing the bribery charges in another federal case against United States Senator Bob Menendez of New Jersey.[5] The charges were not dismissed, but the case ended in a mistrial, with most of the jurors favoring acquittal.[7]
In the aftermath of the
See also
References
- ^ SCOTUSblog coverage
- ^ a b c McDonnell v. United States, No. 15-474, 579 U.S. ___ (2016).
- ^ Greg La Rose, "William Jefferson ordered released from prison after judge drops 7 of 10 counts", New Orleans Times-Picayune, 5 October 2017. Retrieved 7 October 2017
- ISSN 0362-4331. Retrieved June 6, 2018.
- ^ a b c Voreacos, David; Weinberg, Neil (October 11, 2017). "Menendez Judge Suggests He May Dismiss Senator's Bribe Counts". Bloomberg.com. Archived from the original on May 27, 2018. Retrieved June 6, 2018.
- ISBN 9781984879981.
- from the original on June 6, 2018. Retrieved August 7, 2023.
- ^ D'Annunzio, P. J. (August 8, 2017). "Ciavarella Wants to Use 'McDonnell' in Acquittal Bid". The Legal Intelligencer. Retrieved August 9, 2017.
- ^ D'Annunzio, P.J. (March 29, 2019). "Doctor: 3rd Circuit Denies Incarcerated 'Kids-for-Cash' Judge Ciavarella's Bid for New Trial". law.com. Retrieved June 22, 2009.
Further reading
- Brown, George D. (2017). "McDonnell and the Criminalization of Politics". Virginia Journal of Criminal Law. 5 (1). SSRN 2909928.
- Murphy, Christopher (2017). "McDonnell v. United States: Defining Official Action in Public Corruption Law". Duke Journal of Constitutional Law and Public Policy: 269–286.
External links
- Text of McDonnell v. United States, 579 U.S. ___ (2016) is available from: Justia Oyez (oral argument audio) Supreme Court (slip opinion)
- SCOTUSblog coverage