United States v. Robert Worrall

28 F. Cas. 774 (1798)

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United States v. Robert Worrall

United States Circuit Court for the District of Pennsylvania
28 F. Cas. 774 (1798)

Facts

Robert Worrall (defendant) was essentially a primitive contractor who placed a bid to construct a lighthouse in North Carolina for a profit of $1,400. Worrall wrote the Commissioner of Revenue, Tench Coxe, and offered Coxe half of the profits should Worrall’s bid be accepted. Coxe consulted the state attorney general, arranged a meeting, and got Worrall to repeat his offered bribe. At that point, the federal government (plaintiff) indicted Worrall for offering the bribe to Coxe in a letter and then repeating the bribe offer orally. Although the facts were uncontested, the storm brewing in this case was the matter of the legal basis by which the court had jurisdiction against Worrall. That neither the Constitution nor the acts of Congress had proscribed bribery against a federal official was undisputed. Two differing bases for claiming jurisdiction over the case existed—first, because Federal law governed Coxe’s position and his obligation to perform under that position, and Coxe would have been punished under federal law had Coxe accepted the bribe, then the crime of bribery must flow from the federal law. Secondly, in the absence of federal authority, the common law recognized the crime of bribery and would allow for Worrall’s conviction, independent of any federal statutory or constitutional mandate.

Rule of Law

Issue

Holding and Reasoning (Chase, J.)

Dissent (Peters, J.)

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