United States v. Anderson

Cyrus Anderson (defendant) was a registered lobbyist for the mail-order company Spiegel, Inc. (defendant). Anderson met with Daniel Brewster (defendant), a U.S. senator and member of the Senate post-office committee, advised Brewster of Spiegel’s opposition to postal-rate increases, and gave Brewster an envelope containing cash. After a bill was introduced seeking postal-rate increases, Brewster received additional payments from Spiegel through a fictitious political committee. Anderson was charged with bribing Brewster with the intent to influence his actions on postal-rate legislation. Brewster was indicted for accepting bribes. The court instructed the jury on the corrupt-intent element of bribery and the legality of making campaign contributions based on a candidate’s position on legislation. The court refused to give Anderson’s requested instructions that (1) it is not corrupt to attempt to influence a legislator or for a senator to be influenced in his actions on legislation and (2) that the only legal restriction on a lobbyist, who is paid to get legislation passed or defeated, is proper registration. Anderson was convicted. Brewster was acquitted of bribery but convicted for unlawfully receiving gratuities. On appeal, Anderson argued that the district court erred in not giving his requested instructions and that the verdicts were fatally inconsistent.