Honest Services — bribing a police officer

Listen to this article

United States Court of Appeals

Criminal

Honest Services — bribing a police officer

Bribing a police officer to refrain from enforcing the law falls within the scope of 18 U.S.C. 666(a).

“This understanding of the transactional element is consistent with the Supreme Court’s discussion of § 666(a) in Sabri. There, the Court emphasized the statute’s focus on protecting the integrity of federal programmatic funds: ‘Section 666(a)(2) addresses the problem at the sources of bribes, by rational means, to safeguard the integrity of the state, local, and tribal recipients of federal dollars.’ 541 U.S. at 605. Bribes paid to influence the intangible, noncommercial business of a federally funded organization threaten to undermine the integrity of those organizations no less than bribes paid to influence a discrete commercial-like transaction.”

Affirmed.

09-3863 U.S. v. Robinson

Appeal from the United States District Court for the Northern District of Illinois, Darrah, J., Sykes, J.