David Ryan Quoted in Law360 on Seventh Circuit’s Madigan Decision 

Munger, Tolles & Olson Of Counsel David Ryan was quoted in a Law360 article titled, “Madigan Ruling May Offer High Court New Bribery Test.”

The article examines the Seventh Circuit’s decision to uphold the conviction of former Illinois House Speaker Michael Madigan and explores recent U.S. Supreme Court scrutiny of the scope of federal bribery statutes and the definition of a quid pro quo.

In the article, David discusses how the case may raise important questions about what constitutes a sufficiently “specific” official act under Supreme Court precedent. He noted that the Seventh Circuit’s framing of the relevant “question or matter” — such as a general policy objective rather than a clearly defined bill or appointment — could become a focal point if the case reaches the Supreme Court. “What is the specific request being made of the public official?” David asked. “If there’s not a bill or an appointment specified, what is the official act?”

David also highlighted the prosecution’s reliance on circumstantial evidence rather than direct proof of an explicit agreement. He explained that if upheld, the conviction could give prosecutors greater confidence to pursue corruption cases without a clear “smoking gun,” particularly in complex, relationship-driven schemes where explicit quid pro quo arrangements are rarely documented.

Read the Law360 article. (Subscription may be required)