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United States v. Wayne Bryant and R. Michael Gallagher
State senator indicted for honest services fraud based on dual public employment in the legislature and a state medical school. Indicted on both undisclosed conflict and bribery theories, the conflict theory was dismissed pretrial (because the only alleged nondisclosure was the failure to disclose that the job was “really” a bribe, making the conflict theory derivative of the bribery). Bribery also charged under 18 U.S.C. § 666. On appeal defense argued that Skilling renders the jury instructions on bribery erroneous to the extent that they undermined a strict quid pro quo requirement.