[rayiner]

That case doesn’t muddy the water, because it doesn’t address the requirements of bribery law at all. In the trial below, the prosecutors disavowed that they were proceeding on a bribery theory. The jury was never instructed about the required elements of bribery.

The only thing the Supreme Court decided in that case was whether that specific statute encompasses a gratuity theory. That’s illegal for federal officials under a different statute that was not invoked in this case.