Snyder v. United States
In brief
Section 666 punishes bribes, not after-the-fact gratuities that lack a prior agreement to trade official action for payment.
- Where it stands
- Decided
Decided 6-3 · June 26, 2024 · Opinion by Justice Kavanaugh
- What it’s about
- The Supreme Court ruled that a federal anti-corruption law prohibits bribes to state and local officials but does not criminalize gratuities, which are payments made in recognition of past actions without a prior quid pro quo agreement.
- Who it affects
- Federal prosecutors cannot use §666 to prosecute state and local officials solely for post-action thank-you payments without proof of a bribery agreement.
Summary: written with AI from the case record.
What it's about
The decision overturned the conviction of an Indiana mayor who had accepted money after the city purchased garbage trucks.
The decision narrows one federal tool for policing corruption by state and local officials while leaving states and local governments to regulate gratuities within constitutional limits.
Question presented
Does 18 U.S.C. § 666(a)(1)(B) criminalize gratuities, i.e., payments in recognition of actions a state or local official has already taken or committed to take, without any quid pro quo agreement to take those actions?
What the Court decided
Holding
Section 666 proscribes bribes to state and local officials but does not make it a crime for those officials to accept gratuities for their past acts. 71 F. 4th 555, reversed and remanded.
- Result
- Reversed
The vote
- Joined the judgment
- Concurred in a separate opinion
- Dissented
- Wrote an opinion
- Concurring · 1agreed with the result, wrote separately
- Gorsuchwrote separately
From the opinions
“Section 666 proscribes bribes to state and local officials but does not make it a crime for those officials to accept gratuities for their past acts.”
“Officials who use their public positions for private gain threaten the integrity of our most important institutions.”
What's next
The case returns to the lower courts following the reversal and remand. Prosecutors, state agencies, and local governments must apply §666 as limited to bribery and may rely on other lawful rules to address gratuities.
Why it matters
For example, an official who accepts money after awarding a contract is not guilty under this law unless the payment was part of an agreed exchange.
Documents
Docket activity
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AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Case Briefing
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AI analysis generated: Decision Record
Opinion added: Snyder
Opinion added: opinion
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Brief added: Questions Presented
More questions
- What did the Supreme Court rule in Snyder v. United States?
- The Court ruled that §666 criminalizes bribes to state and local officials, but not gratuities for past actions without a prior payment agreement.
- Who won Snyder v. United States?
- James Snyder won by a 6-3 vote. The Court reversed and remanded his conviction.
- What does Snyder v. United States mean for state and local officials?
- They cannot be prosecuted under §666 merely for accepting an after-the-fact gratuity. Prosecutors must show bribery, including an agreed exchange for official action.
- What happens next in Snyder v. United States?
- The lower courts will handle the case after the Supreme Court's reversal and remand. Agencies and governments must apply the Court's narrower reading of §666.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.