McDonnell v. United States

Former Virginia Governor Robert F. McDonnell and his wife were convicted for accepting over $175,000 in loans and gifts from businessman Jonnie Williams, who sought state university research support for his dietary supplement. McDonnell arranged meetings, hosted events, and contacted officials on Williams' behalf. The United States Supreme Court unanimously vacated the convictions on June 27, 2016, holding that the jury instructions adopted an impermissibly broad definition of what constitutes an “official act” under federal bribery laws. Setting up meetings, talking to other officials, or organizing events, without more, does not qualify as a formal exercise of governmental power. The case was remanded, and prosecutors subsequently dropped all charges against the McDonnells.

The Supreme Court vacated the convictions in a unanimous 8-0 ruling, finding that the lower court's definition of an “official act” was overly expansive. The case was remanded to the Court of Appeals; the government later moved to dismiss the remaining charges.

Whether the jury instructions defined “official act” too broadly under 18 U.S.C. § 201, and whether actions such as arranging meetings or hosting events alone constitute the kind of formal governmental decision required for a bribery conviction.

The decision significantly narrowed the reach of federal corruption laws, making it far more difficult to prosecute public officials for “pay-to-play” schemes based on access and influence alone. It reshaped ethical standards in politics, sparked a national debate over the line between legal political conduct and corruption, and prompted calls for clearer legislative standards.