Sabri v. United States

Congress enacted 18 U.S.C. § 666(a)(2) to criminalize bribing officials of state, local, or tribal entities that receive at least $10,000 in federal funds annually. Sabri (defendant), a real estate developer, bribed a Minneapolis official who ran a community development organization receiving about $23 million in federal funds each year, seeking to bypass local zoning and licensing rules. Sabri moved to dismiss his indictment, arguing the statute was unconstitutional because it didn't require proof connecting the bribe to the federal funds; the district court agreed, but the court of appeals reversed, and the Supreme Court granted certiorari.