United States v. Sittenfeld

The defendant was convicted of bribery related to campaign contributions, and his conviction was affirmed on appeal. While further review was still available in the Supreme Court, President Trump issued a pardon. The defendant filed a petition for writ of certiorari, and the government requested that the Supreme Court grant certiorari, vacate the conviction and remand for dismissal of the indictment.

United States v. Sittenfeld

Case Details

Case Analysis

Login is required to view the "Case Analysis" section of the Case Tracker. This content is limited to defense practitioners. Please log in or create a free NACDL account to continue. Non-NACDL members will be prompted to complete a brief attorney attestation form before access is granted.

Login

Case Files

Case Appeals

Final - Date Filed 10/17/23 - 6th Circuit Court of Appeals

See the Analysis section for appeal analysis.

Appeal Details
  • Case Number: 23-3840
  • Date Filed: 10/17/2023
  • Jurisdiction: 6th Circuit Court of Appeals
  • Type: Final
  • Status: Decided

Panel: Bush, John K.; Murphy, Eric E.; Nalbandian, John

Read the Docket

Questions Presented

When the government alleges bribery based solely on lawful campaign contributions, may the defendant be convicted based on evidence that is ambiguous as to whether the public official conditioned any official act on the campaign contributions?

Result on Appeal

The conviction was affirmed in February 2025, but before the mandate issued and the conviction became final, President Trump granted a full pardon to the defendant. Thereafter, the defendant filed a petition for certiorari challenging his conviction, and in response the government, which had simultaneously filed a motion to dismiss with prejudice in the district court, responded to the cert petition with a request that the Supreme Court vacate the conviction and remand for consideration of the motion to dismiss. On May 6, 2026, the Supreme Court granted cert. and vacated the conviction, remanding to the Sixth Circuit.

Appeal Files

  • 02/29/24 - ECF: 58 - Brief - Appellant's reply brief

    Appellant's reply brief

  • 12/11/23 - ECF: 22 - Brief - Appellant brief

    Appellant brief

  • 12/19/23 - ECF: 39 - Brief - Amicus brief of former federal, state, and local elected officials in support of appellant

    Amicus brief of former federal, state, and local elected officials in support of appellant

  • 12/18/23 - ECF: 29 - Brief - Amicus brief of Free Speech Institute in support of appellant

    Amicus brief of Free Speech Institute in support of appellant

  • 02/09/24 - ECF: 55 - Brief - Appellee brief

    Appellee brief

  • 12/18/23 - ECF: 33 - Brief - Amicus brief of former federal officials in support of appellant

    Amicus brief of former federal officials in support of appellant

  • 12/18/23 - ECF: 31 - Brief - Amicus brief of business and civic leaders in support of appellant

    Amicus brief of business and civic leaders in support of appellant

  • 12/18/23 - ECF: 35 - Brief - Amicus brief by former public corruption prosecutors in support of appellant

    Amicus brief by former public corruption prosecutors in support of appellant

  • 12/18/23 - ECF: 27 - Brief - Amicus brief of law professors in support of appellant

    Amicus brief of law professors in support of appellant

  • 07/02/26 - ECF: 85 - Order - Order vacating conviction

    Order vacating conviction

  • 02/11/25 - ECF: 73 - Opinion - Affirming conviction

    Affirming conviction

Continue reading below

Suggest a Case

Know of a federal case that departs from traditional enforcement norms? Let us know.

Suggest a Case

Resources

News of Interest

Case Tracker Feedback

Help us improve the Unusual Case Tracker by sharing your experience and suggestions.

Take Brief Survey

Supported by NFCJ

The NACDL Foundation for Criminal Justice preserves and promotes the core values of the National Association of Criminal Defense Lawyers and the American criminal justice system.

Support Us Now

Explore keywords to find information

Featured Products