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Sabri v. United States

United States Supreme Court
541 U.S. 600 (2004)

Sabri v. United States


Congress enacted 18 U.S.C. §666(a)(2) to provide federal criminal penalties for the giving and receiving of bribes for the benefit of state, local, and tribal officials of entities that receive at least $10,000 in federal funds. Sabri (defendant), a real estate developer, bribed a Minneapolis city official on three separate occasions in an effort to obtain permission to circumvent local licensing and zoning laws. The city official headed a Minneapolis public community development organization, which received approximately $23 million annually in federal funds. The United States government (plaintiff) prosecuted Sabri in district court under 18 U.S.C. §666(a)(2) but Sabri moved to dismiss the indictment. Sabri argued that the statute was unconstitutional because it did not require proof of a connection between the federal funds and the alleged bribe in establishing criminal liability. The district court held for Sabri and dismissed the indictment, but the court of appeals reversed. The United States Supreme Court granted certiorari.

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