In the Courts

On June 27, 2016, the United States Supreme Court vacated the conviction of Virginia's ex-governor Bob McDonnell, who had been found guilty of federal corruption charges in 2014 and sentenced to two years in prison. See McDonnell v. United States, No. 15-474, 2016 WL 3461561 (June 27, 2016).

McDonnell was accused of improperly accepting luxury goods, loans and vacations worth approximately $175,000 from Jonnie R. Williams Sr., a businessman who sought McDonnell's support to test his dietary supplement at Virginia's public universities. McDonnell facilitated meetings between Williams and other public officials to discuss the researching and testing of Williams' product, and hosted events at the Governor's Mansion on Williams' behalf. In its brief to the Supreme Court, the defense stated that these acts were mere “routine political courtesies” and did not amount to corruption. The key issue on appeal was whether McDonnell's conduct constituted an “official act” sufficient to convict him of bribery and extortion under federal corruption law. In its unanimous decision, the Supreme Court chose to “adopt a more bounded interpretation of 'official act'” under which McDonnell's actions would not qualify. Pursuant to 18 U.S.C. ' 201(a)(3), an “official act” is defined as “any decision or action on any question, matter, cause, suit, proceeding or controversy, which may at any time be pending, or which may by law be brought before any public official, in such official's official capacity, or in such official's place of trust or profit.”