Does Section 666 of the Criminal Code cover payments for both past acts and payments related to future acts?

MultiRegion, United States of America

The following excerpt is from U.S. v. Coyne, 4 F.3d 100 (2nd Cir. 1993):

We have recently held, in a case involving these very transactions, that Section 666 covers payments for both past acts--a gratuity theory--and payments related to future acts--a bribery theory, see United States v. Crozier, 987 F.2d 893, 898-99 (2d Cir.1993) (holding Section 666 should be construed to include gratuities). The evidence described in the preceding paragraph is more than sufficient with regard to either theory.

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