Snyder v. United States (23-108)

argument 23-108

Snyder v. United States

Supreme Court of the United States 1h 38m 7 speakers 8 chapters transcribed 8 days ago official recording ↗
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What does the term “corruptly” mean under Section 666 and how does it affect the mens‑rea requirement?

John G. Roberts 0:00
We will hear argument first this morning in case twenty three one hundred eight. Snyder versus United States. Ms. Blatt.
Sarah Blatt 0:07
Mr. Chief Justice, and may it please the Court, Section six hundred six six six six sixty six applies to nineteen million State, local, and tribal officials and anyone else whose employer receives federal benefits, including fourteen million Medicare funded health care workers. Congress did not plausibly subject all of these people to ten years in prison just for accepting gifts, especially when federal officials face only two years for accepting gifts under two hundred and one C. Six sixty six punishes corruptly receiving anything of value intending to be influenced or rewarded. Corruptly intending to be influenced covers classic bribes where officials get upfront payments in exchange for official conduct.
Sarah Blatt 0:50
While corruptly intending to be rewarded, covers bribes paid after the fact and to officials who aren't actually influenced. The government argues corruptly under six six six means wrongful, immoral, depraved or evil. But the government tried this case and countless others on the theory that corruptly just meant knowingly. Regardless, the government's new definition is implausible and stunningly vague. No gratuity statute, that's none whatsoever, uses the word corruptly, and for good reason. The government can't tell you what gifts are corrupts are corrupt. What gift is too much for the doctor who saves your life? Is pornography an immoral gift? The federalism and due process implications of the government's view are gobsmacking.
Sarah Blatt 1:38
All states prohibit bribery, but localities and states take an infinite approaches to gifts and outside compensation. Affirmants would let federal prosecutors second guess all of these judgments. Meanwhile, state and local officials will have no way of knowing what gift would subject them to ten years in prison. Remember, extensive guidance tells federal employees that accepting anything over twenty dollars is a crime. It would be downright Kough Gask to subject State and local officials to a standardless and severe regime where federal interests are at their weakest. I welcome questions.
John G. Roberts 2:14
Ms. Blatt, if I find a lost pet and return it uh to the owner and the owner is grateful and gives me uh ten dollars, that's a reward, right? Even though nothing else happened in advance between the owner and and uh me.
Sarah Blatt 2:29
So yes, divorced from you know a a crime that makes it a corrupt uh corruptly ex giving something of value intending to be rewarded. The word uh reward just divorced from text of a statute, context, common sense, at least in this case, sure. Reward can mean both uh a bribery and a quid pro quo bribery and um uh a gratuity and we think it's very significant in all the statutes that use reward to mean gratuities. They're vastly different in four respects here. They all say when reward is used to mean gratuities, these are cited at page 31 of our brief, they make clear that no quid pro quo payment is required. They say you can't receive any authorized fee or compensation. Also, there are thirteen gratuity statutes identified in the brief.
Sarah Blatt 3:16
Virtually all of them have no express mensrea whatsoever. They have vastly lower penalties, and they almost exclusively apply to Federal officials. And I think that just highlights that gratuity statutes are generally prophylactic rules where the government has a direct interest. And at least here, to use corruptly in a gratuity statute would make this statute a unicorn. It literally has no accepted meaning, it doesn't exist in any other statute. I don't think anyone knows what a corrupt gratuity is. But i if
Elena Kagan 3:46
I I I would think that um uh a s demanding mens rea would cut against you. In other words, if you add a demanding mensrea to the statute one will have less fear that the statute is going to be applied in an overbroad way. So you're using that on your side, but I would think that it's really the government's argument.
Sarah Blatt 4:06
No, a gov uh men's re I can't help you if it's standardless and has no no meaning and just leaves it up to a jury and I guess federal prosecutors

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