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 readSeptember 02, 2014 at 12:00 AM
By
Gary Stein
Eli J. Mark
Gratuities and Honest Services Fraud

As noted in Part One of this article, inSkilling v. United States, 130 S.Ct. 2896 (2010), the U.S. Supreme Court limited the scope of the honest services fraud

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