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United States v. Sun-Diamond Growers of California

United States Supreme Court
138 F.3d 961 (D.C. Cir. 1998), aff'd on other grounds, 526 U.S. 398 (1999)


Facts

Sun-Diamond Growers of California (Sun-Diamond) (defendant) was a trade association whose member cooperatives produced farm commodities. Sun-Diamond was indicted under 18 U.S.C. § 201(c)(1)(A), known as the illegal-gratuity statute, for giving gifts of value to former Secretary of Agriculture Michael Espy. The indictment revealed that at the time the gifts were given, Sun-Diamond stood to benefit from favorable treatment with respect to two matters then before Espy. However, the indictment did not allege a connection between Sun-Diamond’s gifts and the two matters before Espy. Sun-Diamond moved to dismiss the indictment on that ground. The district court denied the motion. After trial, in its instructions to the jury, the district court distinguished an illegal gratuity from the crime of bribery, noting that the bribery statute required a quid pro quo between the giver and the recipient, whereas the illegal-gratuity statute did not. The district court further instructed that unlike the bribery statute, the illegal-gratuity statute required no connection between Sun-Diamond’s intent and a particular official act, and that a conviction could be based on the finding that Sun-Diamond gave the gifts simply because Espy held public office. The jury convicted Sun-Diamond for violating the statute. The court of appeals reversed on the ground that the jury instructions were given in error. The government (plaintiff) requested certiorari.

Rule of Law

Issue

Holding and Reasoning (Scalia, J.)

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