## Facts

- James Snyder, the mayor of Portage, Indiana, oversaw a city effort to improve garbage collection.
- In 2013, after a public bidding process, the city awarded contracts to a truck dealer (Great Lakes Peterbilt) and purchased five trash trucks for about $1.1 million.
- In 2014, after the contracts were awarded and the trucks purchased, the dealer paid Snyder $13,000.
- Snyder characterized the payment as compensation for consulting services; federal prosecutors treated it as an illegal gratuity connected to the contracts.
- A federal jury convicted Snyder under 18 U.S.C. § 666(a)(1)(B), and the district court sentenced him to 21 months’ imprisonment.
- The Seventh Circuit affirmed, concluding that § 666 covers both bribes and gratuities.

## Issues

1. Whether 18 U.S.C. § 666(a)(1)(B) criminalizes gratuities paid to state or local officials as rewards for past official acts, absent a quid pro quo agreement.
2. Whether § 666(a)(1)(B) is limited to bribery—payments made or agreed to in exchange for influencing an official act.

## Decision

- The Supreme Court reversed the judgment upholding Snyder’s conviction.
- The Court held that § 666(a)(1)(B) does not criminalize gratuities to state and local officials for past acts; it reaches only bribery.
- The Court interpreted “intending to be influenced or rewarded” as operating within a bribery framework; “rewarded” does not create a separate gratuities offense.
- Because Snyder’s prosecution was based on a gratuity theory rather than a bribery quid pro quo, his conviction under § 666 could not stand.

## Legal Principles

- Under 18 U.S.C. § 666(a)(1)(B), the government must prove bribery: a corrupt exchange (quid pro quo) involving an intent to influence an official act or decision connected to covered transactions.
- Post hoc payments given as a token of appreciation for completed official action, without a quid pro quo, are not criminal under § 666.
- Statutory context matters: Congress separately criminalized bribery and gratuities for federal officials in 18 U.S.C. § 201, supporting reading § 666 as a bribery-only provision.
- The term “rewarded” in § 666 functions to prevent bribery liability from turning on timing (e.g., payment after an official act) when a corrupt exchange exists.

## Conclusion

The Court confined 18 U.S.C. § 666(a)(1)(B) to bribery and rejected using it to prosecute state and local officials for gratuities paid after official acts without a quid pro quo, requiring reversal of Snyder’s gratuity-based conviction.


Snyder v. United States, 144 S. Ct. 1947 (2024)