Gratuities and Honest Services Fraud

As noted in Part One of this article, in <I>Skilling v. United States</I>, the U.S. Supreme Court limited the scope of the honest services fraud statute 18 U.S.C. ' 1346) to "bribery and kickback" schemes, yet did not define what a "bribery" or "kickback" scheme must entail. So the question becomes this: Must a "bribe or kickback" involve a <I>quid pro quo</I>?

14 minute read September 02, 2014 at 12:00 AM
By
Gary Stein And Eli J. Mark
Gratuities and Honest Services Fraud

As noted in Part One of this article, in Skilling v. United States

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