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Snyder v. United States

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Supreme Court of the United States
Snyder v. United States
Term: 2023
Important Dates
Argued: April 15, 2024
Decided: June 26, 2024
Outcome
reversed and remanded
Vote
6-3
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
Concurring
Neil Gorsuch
Dissenting
Ketanji Brown Jackson • Sonia Sotomayor • Elena Kagan

Snyder v. United States is a case that was decided by the Supreme Court of the United States on June 26, 2024, during the court's October 2023-2024 term. The case was argued before the Supreme Court of the United States on April 15, 2024.

In a 6-3, opinion, the court reversed and remanded the judgment of the United States Court of Appeals for the 7th Circuit, holding that 18 U.S.C. § 666(a)(1)(B) prohibits bribes to state and local officials but does not make it illegal for those officials to accept gratuities for their past actions. Justice Brett Kavanaugh delivered the opinion of the court.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned the legality of paying government officials gratuities under federal bribery law when the official's actions or commitments were made without a quid pro quo agreement. The relevant laws cited in the case are 18 U.S.C. § 666(a)(1)(B), the Fourth Amendment, the Sixth Amendment, and the Speedy Trial Act. Click here to learn more about the case's background.
  • The questions presented: "Whether section 666 criminalizes gratuities, i.e., payments in recognition of actions the official has already taken or committed to take, without any quid pro quo agreement to take those actions."[2]
  • The outcome: In a 6-3, opinion, the court reversed and remanded the judgment of the United States Court of Appeals for the 7th Circuit, holding that 18 U.S.C. § 666(a)(1)(B) prohibits bribes to state and local officials but does not make it illegal for those officials to accept gratuities for their past actions.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the 7th Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:


    Background

    The petitioner is James Snyder, former Mayor of Portage, Indiana (R). He was elected to office in November 2011 and he assumed office in January 2012. In his petition for a writ of certiorari to the U.S. Supreme Court, Snyder referenced his campaign promises to improve the city's waste management system and the local economy by working with local businesses.[4] To that end, Snyder's administration announced two contracts to purchase garbage trucks, one in December 2012, one in November 2013. Snyder appointed Assistant Superintendent of Streets Randy Reeder, a friend of his, to manage the public bidding process. Reeder awarded the contracts to Portage-based truck dealer Great Lakes Peterbilt (GLPB), a company owned by Robert and Stephen Buha. According to the Seventh Circuit Court of Appeals opinion in the case, "Reeder testified at trial that he drafted the bid specifications to favor GLPB. Evidence at trial also showed that Mayor Snyder was in frequent contact with the Buha brothers—but no other bidders—during the bidding process. Less than three weeks after the second contract was awarded, GLPB paid Snyder $13,000."[3] According to Snyder's certiorari petition, the $13,000 from GLPB was paid in January 2014 for his consulting work to be done throughout that year.[4]

    Elsewhere, Snyder's business First Financial Trust Mortgage did not pay payroll taxes in full for 2007, 2008, and 2009 tax years. Consequently, the Internal Revenue Service (IRS) levied the company's bank accounts. Snyder then arranged to run First Financial Trust Mortgage as a division of GVC Mortgage; the latter mortgage company would reimburse Snyder's new company, SRC Properties, so that the money was not subject to IRS levies. Snyder's personal taxes were also late, and IRS levied his personal bank accounts in December 2010 and February 2011. While negotiating a repayment plan, Snyder failed to report his ownership and employment with SRC Properties and GVC Mortgage.[3]

    Snyder was indicted by a federal grand jury in 2016 in the Northern District of Indiana. According to Oyez—a free law project from Cornell Law School’s Legal Information Institute, Justia, and the Chicago-Kent College of Law—"Before, during, and after trial, Snyder argued that the evidence did not support a finding that there was an agreement to exchange money for the truck contracts before they were awarded. Without a prior quid pro quo agreement, he argued, § 666 cannot apply."[5][6] At trial in 2019, Snyder was convicted of federal funds bribery under 18 U.S.C. § 666(a)(1)(B) and for obstructing the IRS by concealing assets and income under 26 U.S.C. § 7212(a) - Attempts to interfere with administration of internal revenue laws. According to the petition for a writ of certiorari, "Section 666 makes it a felony punishable by up to 10 years’ imprisonment for state or local officials to steal state- or local-government property or accept or demand bribes. Section 666 equally applies to private individuals who bribe officials."[4]

    Snyder moved for acquittal on his convictions; the district court denied the motion while granting a new trial on his bribery offense. In March 2021, Snyder was convicted of bribery again by a jury.[3][4]

    On appeal to the United States Court of Appeals for the 7th Circuit, a three-judge panel affirmed the Northern District of Indiana ruling, upholding Snyder's convictions:[3]

    • Snyder claimed that the federal bribery law applied to bribes, not gratuities—he characterized the $13,000 payment from the Buhas was a gratuity. The 7th Circuit rejected this contention, holding, "The governing statutory language does not use the terms "bribe" or "gratuity." The statutory language "influenced or rewarded" easily reaches both bribes and gratuities. ... Accordingly, we follow here our precedents holding that 18 U.S.C. § 666 applies to gratuities and does not require evidence of a prior quid pro quo agreement."[3]
    • Snyder claimed that the government violated his Fourth and Sixth Amendment rights by impinging upon his attorney-client privilege by seizing communications under the power of a warrant he argued was overly broad. The 7th Circuit held that the remedy to the Fourth Amendment claim would not be to dismiss the case, as Snyder claimed it was. The 7th Circuit held that the government's actions occurred before he was indicted, so his Sixth Amendment protections were not yet in effect to be violated. As well, the government did not purposely intrude on his attorney-client privilege, in the court's opinion. As a result, the district court did not err in denying Snyder's motion to dismiss.
    • In addition, Snyder's claim that his right to a speedy trial was violated by the time gap between his trials. The 7th Circuit held that Snyder was more to blame than the government for the delays during the court proceedings and that the delay did not show prejudice. As a result, the circuit court ruled that the district court did not err in denying his motion to dismiss the charges.

    On August 1, 2023, Snyder appealed to the U.S. Supreme Court, asking for review of the bribery charge. SCOTUS accepted the case to its merits docket on December 13, 2023.


    18 U.S.C. § 666 - Theft or bribery concerning programs receiving federal funds

    The legal statute at issue in the case is 18 U.S.C. § 666 - Theft or bribery concerning programs receiving federal funds. Subsection (a)(1)(B) states:Cite error: Invalid <ref> tag; name cannot be a simple integer. Use a descriptive title

    “ (a) Whoever, if the circumstance described in subsection (b) of this section exists—

    (1) being an agent of an organization, or of a State, local, or Indian tribal government, or any agency thereof— ... (B) corruptly solicits or demands for the benefit of any person, or accepts or agrees to accept, anything of value from any person, intending to be influenced or rewarded in connection with any business, transaction, or series of transactions of such organization, government, or agency involving any thing of value of $5,000 or more; or[7]

    		”
    —18 U.S. Code Chapter 31 - EMBEZZLEMENT AND THEFT

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether section 666 criminalizes gratuities, i.e., payments in recognition of actions the official has already taken or committed to take, without any quid pro quo agreement to take those actions.[7] ”

    Oral argument

    Audio

    Audio of oral argument:[8]



    Transcript

    Transcript of oral argument:[9]

    Outcome

    In a 6-3, opinion, the court reversed and remanded the judgment of the United States Court of Appeals for the 7th Circuit, holding that 18 U.S.C. § 666(a)(1)(B) prohibits bribes to state and local officials but does not make it illegal for those officials to accept gratuities for their past actions. Justice Brett Kavanaugh delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Brett Kavanaugh wrote:[1]

    “

    The Government asks this Court to adopt an interpretation of §666 that would radically upend gratuities rules and turn §666 into a vague and unfair trap for 19 million state and local officials. We decline to do so. Section 666 is a vital statute, but its focus is targeted: Section 666 proscribes bribes to state and local officials, while allowing state and local governments to regulate gratuities to state and local officials. Within constitutional bounds, Congress can always change the law if it wishes to do so. But since 1986, it has not, presumably because Congress understands that state and local governments may and often do regulate gratuities to state and local officials. We reverse the judgment of the U. S. Court of Appeals for the Seventh Circuit and remand the case for further proceedings consistent with this opinion.[7]

    		”
    —Justice Brett Kavanaugh

    Concurring opinion

    Justice Neil Gorsuch filed a concurring opinion.

    In his concurring opinion, Justice Gorsuch wrote:[1]

    “

    Call it what you will. The Court today speaks of inferences from the word ‘corruptly,’ the statute’s history and structure, and associated punishments. See ante, at 7. It discusses concerns of fair notice and federalism. Ibid. But the bottom line is that, for all those reasons, any fair reader of this statute would be left with a reasonable doubt about whether it covers the defendant’s charged conduct. And when that happens, judges are bound by the ancient rule of lenity to decide the case as the Court does today, not for the prosecutor but for the presumptively free individual. See United States v. Davis, 588 U. S. 445, 464–465 (2019).[7]

    		”
    —Justice Neil Gorsuch

    Dissenting opinion

    Justice Ketanji Brown Jackson filed a dissenting opinion, joined by Justices Sonia Sotomayor and Elena Kagan .

    In her dissent, Justice Jackson wrote:[1]

    “

    State, local, and tribal governments have an important role to play in combating public corruption, and, of course, their regulations should reflect the values of the communities they serve. I wholeheartedly agree with the majority’s suggestion that, because employees of those governments are our neighbors, friends, and hometown heroes, federal law ought not be read to subject them to prosecution when grateful members of the community show their thanks. See ante, at 1.

    But nothing about the facts of this case implicates any of that kind of conduct. And the text of §666 clearly covers the kind of corrupt (albeit perhaps non-quid pro quo) payment Snyder solicited after steering the city contracts to the dealership. Because reading §666 to prohibit gratuities—just as it always has—poses no genuine threat to common gift giving, but does honor Congress’s intent to punish rewards corruptly accepted by government officials in ways that are functionally indistinguishable from taking a bribe, I respectfully dissent. [7]

    		”
    —Justice Ketanji Brown Jackson

    Text of the opinion

    Read the full opinion here.

    October term 2023-2024

    See also: Supreme Court cases, October term 2023-2024

    The Supreme Court began hearing cases for the term on October 2, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[10]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 Supreme Court of the United States, "SNYDER v. UNITED STATES," decided June 26, 2024
    2. ↑ 2.0 2.1 U.S. Supreme Court, "No. 23-108," accessed December 13, 2023
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 U.S. Court of Appeals for the 7th Circuit, United States v. Snyder, decided June 15, 2023
    4. ↑ 4.0 4.1 4.2 4.3 U.S. Supreme Court, "Snyder v. United States ON PETITION FOR A WRIT OF CERTIORARI," filed August 1, 2023
    5. ↑ Oyez, "Snyder v. United States," accessed March 21, 2024
    6. ↑ Oyez, "About," accessed March 21, 2024
    7. ↑ 7.0 7.1 7.2 7.3 7.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    8. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued April 15, 2024
    9. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued April 15, 2024
    10. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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