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
Argued April 27, 2016
Decided June 27, 2016
Full case nameRobert F. McDonnell, Petitioner v. United States
Docket no.15-474
Citations579 U.S. ___ (more)
136 S. Ct. 2355; 195 L. Ed. 2d 639
Opinion announcementOpinion announcement
Case history
PriorUnited 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
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan
Case opinion
MajorityRoberts, 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]

See also

References
  1. SCOTUSblog coverage
  2. McDonnell v. United States, No. 15-474, 579 U.S. ___ (2016).
  3. 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
  4. "Corruption Case Against Senator Menendez Ends in Mistrial". The New York Times. 2017-11-16. ISSN 0362-4331. Retrieved 2018-06-06.
  5. "Menendez Judge Suggests He May Dismiss Senator's Bribe Counts". Bloomberg.com. 2017-10-11. Retrieved 2018-06-06.
  6. "Menendez Judge Suggests He May Dismiss Senator's Bribe Counts". Bloomberg.com. 2017-10-11. Retrieved 2018-06-06.

Further reading
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