Snyder v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Snyder v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Snyder v. United States.
The Supreme Court addressed whether 18 U.S.C. § 666 criminalizes the acceptance of gratuities by state and local officials. The Court concluded that § 666 is a bribery statute, not a gratuities statute, emphasizing the distinction between bribery and gratuities in federal law. The decision reversed the Seventh Circuit's affirmation of James Snyder's conviction under § 666.
Holding
The single most important “bottom line” of what the Court decided in Snyder v. United States.
The Court held that § 666 proscribes bribes to state and local officials but does not make it a crime for those officials to accept gratuities for their past acts.
Constitutional Concepts
These are the Constitution-related themes that appear in Snyder v. United States. Click a concept to see other cases that involve the same idea.
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Why State–Federal Power is relevant to Snyder v. United States
The Court's decision emphasizes the federalism principle that states have the prerogative to regulate interactions between state officials and constituents, and that federal law should not override these state decisions lightly.
Syllabus excerpt (verbatim)Interpreting § 666 as a gratuities statute would significantly infringe on bedrock federalism principles. Generally, States have the 'prerogative to regulate the permissible scope of interactions between state officials and their constituents.'
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Why Void for Vagueness is relevant to Snyder v. United States
The Court discusses the lack of clear guidance on what constitutes a criminal gratuity under § 666, which could lead to arbitrary enforcement and uncertainty for state and local officials.
Syllabus excerpt (verbatim)The Government's so-called guidance would leave state and local officials entirely at sea to guess about what gifts they are allowed to accept under federal law, with the threat of up to 10 years in federal prison if they happen to guess wrong.
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Why Preemption is relevant to Snyder v. United States
The decision involves the issue of whether federal law under § 666 should preempt state laws regarding the acceptance of gratuities by state and local officials.
Syllabus excerpt (verbatim)Reading § 666 to create a federal prohibition on gratuities would suddenly subject 19 million state and local officials to a new and different regulatory regime for gratuities.
Key Quotes
Short excerpts from the syllabus in Snyder v. United States that support the summary and concepts above.
Section 666 proscribes bribes to state and local offcials but does not make it a crime for those offcials to accept gratuities for their past acts.
The statutory text strongly suggests that § 666—like § 201(b)—is a bribery statute, not a gratuities statute.
Reading § 666 to create a federal prohibition on gratuities would suddenly subject 19 million state and local offcials to a new and different regulatory regime for gratuities.
