Sun-Diamond Growers of California was a trade association engaged in marketing and lobbying…

Sun-Diamond Growers of California was a trade association
engaged in marketing and lobbying activities on behalf of its member
cooperatives, which were owned by 5,000 producers of raisins, figs, walnuts,
prunes, and hazelnuts. A federal grand jury indicted Sun-Diamond for an alleged
violation of the illegal gratuity statute, 18 U.S.C. § 201(1)(A), which
criminalizes a private party’s giving of “anything of value” to a public
official “for or because of any official act performed or to be performed” by
the public official. According to the indictment, SunDiamond violated the
statute by
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Sun-Diamond Growers of California was a trade association
engaged in marketing and lobbying activities on behalf of its member
cooperatives, which were owned by 5,000 producers of raisins, figs, walnuts,
prunes, and hazelnuts. A federal grand jury indicted Sun-Diamond for an alleged
violation of the illegal gratuity statute, 18 U.S.C. § 201(1)(A), which
criminalizes a private party’s giving of “anything of value” to a public
official “for or because of any official act performed or to be performed” by
the public official. According to the indictment, SunDiamond violated the
statute by giving thenSecretary of Agriculture Michael Espy gratuities valued
at approximately $5,900 (tickets to the U.S. Open Tennis Tournament, luggage,
meals, a framed print, and a crystal bowl). The indictment alluded to two
Department of Agriculture–related matters in which Sun-Diamond had an interest
in favorable treatment at the time Sun-Diamond gave the gifts to Secretary
Espy. Nevertheless, the indictment did not allege a specific connection between
either of the two matters and Sun-Diamond’s conferral of the gifts. A federal
district court jury found Sun-Diamond guilty. Holding that the district judge
erred in instructing the jury that “it is sufficient if Sun-Diamond provided
Espy with unauthorized compensation simply because he held public office,” the
U.S. Court of Appeals for the District of Columbia Circuit reversed and
remanded. The U.S. Supreme Court granted certiorari. How did the Supreme Court
rule?

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