Sun-Diamond Growers of California was a trade association engaged in marketing and lobbying…

Sun-Diamond Growers of California was a trade association engaged in marketing and lobbying activities on behalf of its member cooperatives, which were owned by 5,000 producers of raisins, figs, walnuts, prunes, and hazelnuts. A federal grand jury indicted Sun-Diamond for an alleged violation of the illegal gratuity statute, 18 U.S.C. § 201(1)(A), which criminalizes a private party’s giving of “anything of value” to a public official “for or because of any official act performed or to be performed” by the public official. According to the indictment, Sun Diamond violated the statute by giving then Secretary of Agriculture Michael Espy gratuities valued at approximately $5,900 (tickets to the U.S. Open Tennis Tournament, luggage, meals, a framed print, and a crystal bowl). The indictment alluded to two Department of Agriculture–related matters in which Sun-Diamond had an interest in favorable treatment at the time Sun-Diamond gave the gifts to Secretary Espy. Nevertheless, the indictment did not allege a specific connection between either of the two matters and Sun-Diamond’s conferral of the gifts. A federal district court jury found Sun-Diamond guilty. Holding that the district judge erred in instructing the jury that “it is sufficient if Sun-Diamond provided Espy with unauthorized compensation simply because he held public office,” the U.S. Court of Appeals for the District of Columbia Circuit reversed and remanded. The U.S. Supreme Court granted certiorari. How did the Supreme Court rule?

 

 

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