Elkan Abramowitz, left, and Jonathan Sack. Courtesy photos 
In June, the Supreme Court held in Snyder v. United States, 144 S. Ct. 1947 (2024), that a federal anti-corruption statute applied only to "bribes," not "gratuities." The majority interpreted the statute narrowly on the basis of six considerations: text, statutory history, statutory structure, statutory punishments, federalism, and fair notice. In his concurring opinion, Justice Neil Gorsuch put the matter more starkly: "Whatever the label, lenity is what's at work behind today's decision, just as it is in so many others. Rightly so."
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