Sixth Circuit Interprets Bribery Statue

 The May issue of The Informer, the publication of the Federal Law Enforcement Training Center's Legal Division, highlights a recent bribery case, U.S. v. Abbey, 560 F.3d 513 (6th Cir. 2009). The Sixth Circuit summarized its holding as follows:

Abbey’s appeal boils down to a single assertion: that the government, to sustain a conviction under 18 U.S.C. § 666 or the Hobbs Act, 18 U.S.C. § 1951, must prove a direct link between a specific gift given to a public official and an explicit promise by that official to perform a specific, identifiable official act in return. Though Abbey is correct that the government did not prove such a link at trial and that the jury instructions did not so instruct, we nevertheless reject his argument because neither statute contains such a heightened requirement. We thus affirm Abbey’s convictions and sentence.