McDonnell v. United States
The Supreme Court threw out former Virginia Governor Robert McDonnell's corruption convictions, ruling that the jury had been told to use too broad a definition of the "official act" a public official must perform to be guilty of bribery.
The Court held that arranging meetings, attending events, and making calls on a favor-seeker's behalf are not, by themselves, official acts unless they involve a decision or action on a specific, pending government matter — narrowing what prosecutors can call bribery nationwide.
How it got here: A jury convicted McDonnell after a federal trial court's instructions; the Fourth Circuit affirmed; McDonnell asked the Supreme Court to review the definition of "official act."
The Case in Depth
What happened
Robert McDonnell, then Governor of Virginia, and his wife accepted $175,000 in loans, gifts, and other benefits from businessman Jonnie Williams, whose company made a nutritional supplement called Anatabloc. Williams wanted the Governor's help getting Virginia's public universities to study the product. Federal prosecutors charged McDonnell with trading loans and gifts for "official acts" like arranging meetings and hosting events for Williams.
The question before the Court
Did a Virginia governor commit an "official act" under federal bribery law just by setting up meetings, hosting events, and making calls for a businessman who gave him gifts and loans?
The Court's answer
No — the Court ruled that simply arranging meetings, contacting other officials, or hosting events, without more, does not count as an "official act" under the federal bribery law. An official act requires a decision or action (or an agreement to make one) on a specific, focused government matter that is pending or could be brought before an official — something like initiating a research study, not just talking about one.
Because the jury here was told that routine activities like setting up meetings could themselves qualify as official acts, and that a broad goal like "economic development" could count as the relevant government matter, the instructions were too broad. The Court could not say this error was harmless, so it threw out McDonnell's convictions and sent the case back for the lower courts to decide whether the evidence, properly understood, was enough to convict him.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
The ruling limits how prosecutors can charge public officials with corruption for routine constituent services like setting up meetings or attending events. It protects officials from prosecution for everyday interactions with people who happen to have given them gifts or donations, while still leaving room to prosecute officials who actually trade specific government decisions for money.
What changes now
The case goes back to the lower courts. The Fourth Circuit must now decide, under the Supreme Court's narrower definition of "official act," whether there was enough evidence to convict McDonnell at all. If the evidence is sufficient, he could face a new trial; if not, the charges against him must be dismissed. The Court did not decide that question itself.
What this does not decide
The Court did not decide whether McDonnell is guilty or innocent, or whether the evidence against him was sufficient under the new, narrower definition of "official act." It left that question for the Fourth Circuit to resolve on remand, and did not rule on his wife's separate, still-pending appeal.
How the Court got there
The legal reasoning, step by step
- The Court read the bribery statute's definition of "official act" as having two parts: a "question, matter, cause, suit, proceeding or controversy" that is pending or could be brought before an official, and a decision or action (or agreement to decide or act) on that question or matter.
- Applying the interpretive principle noscitur a sociis — the idea that an ambiguous word takes its meaning from the more specific words around it — the Court read "question" and "matter" narrowly, so they must resemble a formal government proceeding like a lawsuit or hearing, not just any topic of interest.
- The Court concluded that a typical meeting, phone call, or social event is not itself a qualifying "question" or "matter," and that a broad policy goal like general economic development is too vague and unfocused to count either — the matter must be something specific enough to be tracked and resolved.
- Relying on its earlier decision in United States v. Sun-Diamond Growers, the Court held that hosting an event or attending a meeting related to a pending matter is not itself a "decision or action" on that matter; something more is needed, such as pressuring another official or giving advice meant to produce an official decision.
- The Court found that reading "official act" as broadly as the government proposed would raise serious constitutional problems, including vagueness and interference with how officials interact with constituents, reinforcing the narrower reading it adopted.
Doctrinal impact
Cases affected by this decision
Reaffirms United States v. Sun-Diamond Growers of Cal. (526 U. S. 398)
The Court relied on this earlier case to show that hosting events or meetings, alone, is not an official act.