Political corruption in the United States has become more and more prevalent in recent years. These days it seems difficult to turn on the news without hearing accusations of a public official caught in a scandal. Despite the frequency of the corrupt acts, however, the federal government remains
largely unable to hold state actors accountable.

The U.S. Supreme Court has consistently overturned federal convictions of state officials charged with committing corrupt acts. The issue in these cases is not the lack of corruption or proof of the acts but rather, the lack of laws that adequately criminalize the corrupt conduct. As a result, the same corrupt actions being publicly denounced in the news are being excused in the justice system.

This Note examines the Court’s recent corruption cases and analyzes the rationales behind them. This Note then applies this analysis to Kelly v. United States, the most recent case in the federal corruption saga, to evaluate where the Court stands on federal corruption.

Ultimately, this Note concludes that, in Kelly, the Court is sending a clear message to Congress: amend the corruption laws to properly cover the conduct. It then proposes an amended version of the current law that takes into account the analysis of Kelly and other federal corruption cases.