Term: 2015
Docket: 15-474
Mcdonnell v. United States
- Pro
15-474 MCDONNELL V. UNITED STATES DECISION BELOW: 792 F.3d 478 GRANTED LIMITED TO QUESTION 1 PRESENTED BY THE PETITION. CERT. GRANTED 1/15/2016 QUESTION PRESENTED: I. Under the federal bribery statute, Hobbs Act, and honest-services fraud statute, 18 U.S.C. §§ 201, 1346, 1951, it is a felony to agree to take "official action" in exchange for money, campaign contributions, or any other thing of value. The question presented is whether "official action" is limited to exercising actual governmental power, threatening to exercise such power, or pressuring others to exercise such power, and whether the jury must be so instructed; or, if not so limited, whether the Hobbs Act and honest-services fraud statute are unconstitutional. II. In Skilling v. United States, this Court held that juror screening and voir dire are the primary means of guarding a defendant's right to an impartial jury against the taint of pretrial publicity. 561 U.S. 358, 388-89 (2010). The question presented is whether a trial court must ask potential jurors who admit exposure to pretrial publicity whether they have formed opinions about the defendant's guilt based on that exposure and allow or conduct sufficient questioning to uncover bias, or whether courts may instead rely on those jurors' collective expression that they can be fair. LOWER COURT CASE NUMBER: 15-4019
In McDonnell v. United States, the Supreme Court unanimously overturned former Virginia Governor Robert F. McDonnell's corruption conviction in 2015. The case centered on whether McDonnell had performed "official acts" in exchange for $175,000 worth of gifts and loans from a wealthy businessman seeking state university research into his dietary supplement product. The court ruled that setting up meetings or calling officials — without more — does not count as an official act under federal bribery laws, thus narrowing the definition of what constitutes an illegal quid pro quo action by public officials. This ruling was significant because it set a high bar for prosecuting political corruption cases.
In the dissenting opinion for McDonnell v. United States, Justice Elena Kagan, joined by Justice Ruth Bader Ginsburg, argued that the majority's interpretation of "official act" was too narrow and could potentially allow public officials to sell access to their time and influence without fear of prosecution. They contended that a public official should not be allowed to accept gifts in exchange for arranging meetings or making phone calls on someone else's behalf because such actions are part of an official’s duties. The dissenters believed this decision would make it more difficult for prosecutors to hold corrupt politicians accountable as they can now argue that their actions did not constitute "official acts". They also expressed concern about how this ruling might impact future corruption cases.
