In the 1893 case of Evans v. United States, the Supreme Court ruled on a matter concerning bribery and public officials. The defendant, Evans, was a government revenue officer who accepted money from distillers in exchange for not enforcing certain tax laws against them. He argued that he could not be convicted of bribery because he did not actually perform or neglect any official duties as a result of accepting the bribe; rather, he simply took advantage of his position to extract money from those who feared enforcement action. The Supreme Court disagreed with this argument and upheld his conviction. They held that it is enough for an official to accept something of value under circumstances where such acceptance might influence their performance or non-performance of duties - actual alteration in behavior need not be proven. This decision broadened the scope for prosecuting corruption among public officials by focusing on potential conflicts between personal gain and duty rather than requiring proof that corrupt payments directly resulted in specific actions or omissions.

In the dissenting opinion for Evans v. United States, Justice Brewer argued that the majority's interpretation of the federal bribery statute was too broad and could potentially criminalize innocent behavior. He contended that a public official should only be guilty of accepting a bribe if they agreed to perform an illegal act or neglect their duties in exchange for money or other benefits. In this case, he believed there was no evidence showing that Evans had promised to do anything unlawful when he accepted money from private individuals who were seeking his assistance with legal matters related to his position as Commissioner of Internal Revenue. Therefore, according to Justice Brewer, Evans' actions did not constitute bribery under existing law.