McDonnell v. United States
McDonnell v. United States, 579 U.S. ___ (2016), was a United States Supreme Court case concerning the appeal of former Virginia Governor Robert F. McDonnell's conviction under the Hobbs Act.[1][2] At issue on appeal was whether the definition of "official act" within the federal bribery statutes encompassed the actions for which McDonnell had been convicted, and whether the jury had been properly instructed on this definition at trial.[2]
McDonnell v. United States | |
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Argued April 27, 2016 Decided June 27, 2016 | |
Full case name | Robert F. McDonnell, Petitioner v. United States |
Docket no. | 15-474 |
Citations | 579 U.S. ___ (more) 136 S. Ct. 2355; 195 L. Ed. 2d 639 |
Opinion announcement | Opinion announcement |
Case history | |
Prior | United States v. McDonnell, 64 F. Supp. 3d 783 (E.D. Va. 2014); affirmed, 792 F.3d 478 (4th Cir. 2015); cert. granted, 136 S. Ct. 891 (2016). |
Holding | |
An "official act" within the federal bribery statutes does not include merely setting up a meeting, calling another public official, or hosting an event. | |
Court membership | |
| |
Case opinion | |
Majority | Roberts, joined by unanimous |
Laws applied | |
Hobbs Act, Honest services fraud |
In light of the court's findings, US District Judge T. S. Ellis III of Virginia ruled on an appeal and dropped seven of ten charges for which former Representative William J. Jefferson of New Orleans was convicted in 2012. He ordered him released from prison on October 5, 2017, pending a new sentence or action from the government.[3]
Opinion of the Court
Chief Justice John Roberts authored the unanimous opinion.[2] McDonnell's conviction was vacated on the grounds that the meaning of "official act" does not include merely setting up a meeting, calling another public official, or hosting an event.
Impact
The ruling narrowed the legal definition of public corruption and made it harder for prosecutors to prove that a political official engaged in bribery.[4][5]
According to Bloomberg News, the ruling "appears to have opened the floodgates for reversals of high-profile public corruption cases, including William Jefferson, a former Louisiana congressman. Former New York State Assembly Speaker Sheldon Silver; Dean Skelos, a former majority leader of the New York state senate; and Skelos’s son, Adam Skelos, have also had corruption convictions overturned over the past few months on similar grounds."[6]
A federal case against New Jersey Senator Bob Menendez was dismissed by United States District Court for the District of New Jersey, which cited the Supreme Court ruling.[6]
References
- SCOTUSblog coverage
- McDonnell v. United States, No. 15-474, 579 U.S. ___ (2016).
- Greg La Rose, "William Jefferson ordered released from prison after judge drops 7 of 10 counts", New Orleans Times-Picayune, 5 October 2017. Retrieved 7 October 2017
- "Corruption Case Against Senator Menendez Ends in Mistrial". The New York Times. 2017-11-16. ISSN 0362-4331. Retrieved 2018-06-06.
- "Menendez Judge Suggests He May Dismiss Senator's Bribe Counts". Bloomberg.com. 2017-10-11. Retrieved 2018-06-06.
- "Menendez Judge Suggests He May Dismiss Senator's Bribe Counts". Bloomberg.com. 2017-10-11. Retrieved 2018-06-06.
Further reading
- Brown, George D. (2017). "McDonnell and the Criminalization of Politics". Virginia Journal of Criminal Law. 5 (1). SSRN 2909928.
- Murphy, Christopher (2017). "McDonnell v. United States: Defining Official Action in Public Corruption Law". Duke Journal of Constitutional Law and Public Policy: 269–286.
External links
- Text of McDonnell v. United States, 579 U.S. ___ (2016) is available from: Justia Oyez (oral argument audio) Supreme Court (slip opinion)
- SCOTUSblog coverage