Supreme Court Decides Snyder v. United States

On June 26, 2024, the U.S. Supreme Court decided Snyder v. United States, No. 23-108, holding that federal statute 18 U. S. C. § 666, which makes it a crime for most state and local officials to “corruptly” solicit, accept, or agree to accept “anything of value” “intending to be influenced or rewarded in connection with” any official business or transaction worth $5,000 or more, does not prohibit covered officials from accepting gratuities given based on their past acts.

While James Snyder was the mayor of Portage, Indiana, the city awarded two contracts to, and purchased $1.1 million in trash trucks from, local trucking company Great Lakes Peterbilt. The following year, Peterbilt cut a $13,000 check to Snyder. Snyder said that the payment was for his consulting services as a contractor for Peterbilt. But the federal government charged Snyder with accepting an illegal gratuity in violation of § 666(a)(1)(B). A federal jury ultimately convicted Snyder, and the district court sentenced him to one year and nine months in prison. The Seventh Circuit affirmed.

The Supreme Court reversed and remanded, holding that § 666 criminalizes only bribes, not gratuities. The Court explained that the statutory text of § 666 was modeled after the federal bribery statute for federal officials, 18 U. S. C. § 201(b). Both § 666 and § 201(b) have an express mental-state requirement: § 201(b) “requires an official to have a corrupt state of mind and to accept (or agree to accept) a payment intending to be influenced in an official act” and § 666 requires an official to “corruptly” solicit, accept, or agree to accept “anything of value[ ].” “By contrast, § 666 bears little resemblance to [the federal anti-gratuity provision] § 201(c), which contains no express [mental state] requirement.” The Court further explained that interpreting § 666 as applying to gratuities would significantly infringe on bedrock federalism principles because States have generally had the prerogative to regulate the permissible scope of interactions between state officials and their constituents.

Because the payment to Snyder was a gratuity, it did not violate § 666. The Court noted, however, that a gratuity that does not violate § 666 may still be unethical or illegal under other federal, state, or local laws.

Justice Kavanaugh delivered the opinion of the Court, in which Chief Justice Roberts, and Justices Thomas, Alito, Gorsuch, and Barrett joined. Justice Gorsuch filed a concurring opinion. Justice Jackson filed a dissenting opinion, in which Justices Sotomayor and Kagan joined.