Key SCOTUS Cases – Sabri v. United States

by Professor Byron L. Warnken on August 25, 2010

Sabri v. United States, 541 U. S. 600 (2004).

Art. I. (Legislative Branch), § 8 (Enumerated Powers), Cl. 1 (Spending Clause):  

Defendant was charged with bribery of official, under 18 U.S.C. § 666(a)(2), which imposes federal criminal penalties for corruptly giving, offering, or agreeing to give anything of value to any person, with intent to influence or reward agent of organization or State, in any business or transaction of organization, government, or agency involving value of $5,000.  Defendant argued that section 666(a)(2) was unconstitutional violation of Spending Clause because the statute did not require a connection between a bribe and federal money.  Supreme Court disagreed, holding that Congress has broad authority under the Spending Clause to appropriate federal monies to promote the general welfare.  Section 666(a)(2) addresses the source of bribes, by rational means, to safeguard integrity of state, local, and tribal recipients of federal dollars.  It is sufficient that Congress conditioned the offense on a threshold amount of federal money, thus defining federal interest.

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