The Honest Services of Public Officials

THIS CASEBOOK contains a selection of U. S. Court of Appeals decisions that analyze and discuss issues surrounding the crime of honest-services fraud. * * * The statutes ] do not impose a universal requirement that bribe payors and payees have a meeting of the minds about an official act. A payor defendant completes the crimes of honest-services and federal-funds bribery as soon as he gives or offers payment in exchange for an official act, even if the payee does nothing or immediately turns him in to law enforcement. See 18 U.S.C. 201(b)(1)(A) and 18 U.S.C. 666(a)(2). * * * Section 666 permits conviction for corrupt payment "in connection with any business, transaction or series of transactions ... involving anything of value of $5,000 or more." 18 U.S.C. 666(a)(2). I]t is "not necessary for the government to link any particular payment to any particular action undertaken by" the government agent, and the bribe "may be paid with the intent to influence a general course of conduct." United States v. Redzic, 627 F.3d 683, 692 (8th Cir. 2010).US v. Suhl, 885 F. 3d 1106 (8th Cir. 2018)