Ring v. United States

Brief of Amici curiae National Association of Criminal Defense Lawyers and Rutherford Institute in Support of Petition for Certiorari.

Brief filed: 07/17/2013


Ring v. United States

United States Supreme Court; Case No. 12-1462

Prior Decision

Decision below 706 F.3d 460 (D.C. Cir. Jan. 25, 2013) (No. 11-3100).


The Court should grant certiorari to make clear that the honest services fraud statute requires the government to prove bribery. The honest services fraud statute is unconstitutionally vague unless limited to bribery, as Skilling requires. The standard applied in this case to prove honest services fraud is inconsistent with this Court’s rulings. The admission of evidence of legal and constitutionally protected campaign contributions in this case, in contravention of this Court’s rulings, will criminalize, and thereby chill, constitutionally protected conduct.

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Paul F. Enzinna and Evan N. Turgeon, Brown Rudnick LLP, Washington, DC.