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Authors

Seth Lewis

Publication Date

5-28-2025

Document Type

Casenote

Abstract

The Supreme Court of the United States determined that the federal bribery statute regarding state and local officials did not include gratuities in Snyder v. United States. In Snyder, James Snyder was convicted of accepting an illegal gratuity under 18 U.S.C. § 666 and appealed his conviction. The Court’s decision addressed the split in the United States Courts of Appeals regarding whether 18 U.S.C. § 666 criminalized gratuities, payments made after an official’s act without a prior agreement, along with bribes, payments made with a prior agreement. The Court held that 18 U.S.C. § 666 only criminalized bribes and did not criminalize gratuities. The Court further held that it is up to the state and local governments to regulate gratuities made to their officials. In placing the officials being offered the gratuities in charge of regulating which ones they are allowed to accept, the Court determined it was best to “put the foxes in charge of guarding the henhouse.”

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