Snyder v. United States
603 U. S. ____ (2024)
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Rule of Law:
The federal anti-corruption statute, 18 U.S.C. § 666, which criminalizes payments to state and local officials intending to be 'influenced or rewarded,' is a bribery statute that requires a quid pro quo agreement and does not criminalize the acceptance of gratuities paid after an official act without a prior agreement.
Facts:
- James Snyder served as the mayor of Portage, Indiana.
- In 2013, while Snyder was mayor, the City of Portage awarded two contracts to a local truck company, Great Lakes Peterbilt.
- The city purchased five trash trucks from Great Lakes Peterbilt for approximately $1.1 million.
- In 2014, after the contracts were awarded, Great Lakes Peterbilt issued a $13,000 check to Snyder.
- Snyder maintained that the payment was for consulting services he provided to the company, while federal prosecutors contended it was a gratuity for awarding the city contracts.
Procedural Posture:
- The United States charged James Snyder in the U.S. District Court with violating 18 U.S.C. § 666(a)(1)(B).
- A federal jury convicted Snyder of accepting an illegal gratuity.
- The District Court sentenced Snyder to 1 year and 9 months in prison.
- Snyder, as the appellant, appealed to the U.S. Court of Appeals for the Seventh Circuit, arguing that § 666 criminalizes only bribes.
- The Seventh Circuit affirmed the conviction, relying on its precedent that § 666 covers both bribes and gratuities.
- The U.S. Supreme Court granted Snyder's petition for a writ of certiorari to resolve a circuit split on the issue.
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Issue:
Does 18 U.S.C. § 666(a)(1)(B), which makes it a crime for state and local officials to 'corruptly' accept anything of value 'intending to be influenced or rewarded,' criminalize the acceptance of gratuities paid after an official act without a prior quid pro quo agreement?
Opinions:
Majority - Justice Kavanaugh
No. Section 666 is a bribery statute, not a gratuities statute, and therefore does not criminalize the acceptance of after-the-fact payments without a prior quid pro quo agreement. The Court's conclusion is based on six reasons: (1) the statutory text, particularly the use of 'corruptly,' aligns with the federal bribery statute (§ 201(b)), not the gratuities statute (§ 201(c)); (2) the statute's history shows Congress amended it in 1986 to resemble the bribery statute; (3) the statutory structure is unusual for combining bribery and gratuities, which are distinct crimes; (4) the punishment scheme would be anomalous, authorizing a 10-year sentence for a local official's gratuity versus 2 years for a federal official's; (5) principles of federalism caution against federal intrusion into state and local government ethics regulation; and (6) the government's interpretation would fail to provide fair notice to 19 million state and local officials about what conduct is criminal. The term 'rewarded' serves to close loopholes in bribery prosecutions, not to expand the statute to cover gratuities.
Concurring - Justice Gorsuch
No. The statute is sufficiently ambiguous about whether it covers the defendant's conduct to trigger the rule of lenity. When a criminal statute is ambiguous, it must be interpreted in favor of the defendant, not the prosecutor. This principle, sometimes called 'fair notice' or 'fair warning,' ensures that individuals are not punished for conduct that is not clearly prohibited, and it is the underlying principle at work in the Court's decision.
Dissenting - Justice Jackson
Yes. The plain text of Section 666, which expressly criminalizes accepting a payment 'intending to be... rewarded,' unambiguously covers gratuities. The majority ignores this clear language, elevating its own federalism policy concerns over congressional intent. The statute's other elements, particularly the requirements that the official act 'corruptly' and that the transaction involve a significant value, provide sufficient guardrails to prevent prosecution for innocuous, everyday gifts. The majority's decision overrides Congress's clear choice to protect federal funds from being 'frittered away in graft' by state and local officials.
Analysis:
This decision significantly narrows the scope of a key federal public corruption statute, resolving a circuit split in favor of a more limited application. By defining 18 U.S.C. § 666 as a bribery-only statute, the Court requires federal prosecutors to prove a quid pro quo agreement, making it more difficult to prosecute officials who receive payments after an official act without evidence of a prior deal. This ruling reinforces federalism principles by preserving the authority of state and local governments to regulate gratuities for their own officials and continues the Roberts Court's trend of narrowly construing broad federal criminal statutes to avoid vagueness and ensure fair notice.
