Post-Snyder § 666 Bribery in the Seventh Circuit: Quid Pro Quo Required, No “Magic Words,” and “Corruptly” Means Intent to Trade Value for Influence

1. Introduction

United States v. Charles Cui (7th Cir. Jan. 9, 2026) arises from federal corruption charges tied to efforts to secure Chicago City Hall influence. The government alleged that Charles Cui, a commercial property owner, bribed then-Alderman Edward Burke by offering lucrative property-tax appeal business to Burke’s private law firm in order to obtain Burke’s assistance with a disputed pole-sign permit at the Chicago Department of Buildings (“CDOB”).

After a six-week jury trial, Cui was convicted of: (1) federal programs bribery, 18 U.S.C. § 666(a)(2); (2) three counts under the Travel Act, 18 U.S.C. § 1952(a)(3) (predicated on Illinois bribery and commercial bribery); and (3) making materially false statements, 18 U.S.C. § 1001(a)(2). He challenged the sufficiency of the evidence, the § 666 jury instructions (including the meaning of quid pro quo and “corruptly”), admission of a photoshopped photograph under Federal Rule of Evidence 404(b), and aspects of sentencing (including a U.S.S.G. § 3C1.1 obstruction enhancement and alleged sentencing disparity).

The decision is especially significant because it applies—and operationalizes—the Supreme Court’s post-trial clarification in Snyder v. United States, 603 U.S. 1 (2024) that § 666 criminalizes bribes, not gratuities.

2. Summary of the Opinion

The Seventh Circuit affirmed in full. It held:

The evidence supported bribery under § 666(a)(2) even after Snyder v. United States, 603 U.S. 1, 19 (2024), because the jury could find Cui offered tax-appeal business to influence Burke’s future efforts with CDOB.
Even assuming a “preexisting agreement” is required, the evidence permitted the jury to find an agreement existed before Burke acted; no formal, written contract was necessary.
The § 666(c) “bona fide salary, wages, fees” safe harbor did not protect Cui where the “legitimate” professional engagement was the alleged bribe itself.
The Travel Act convictions stood because the evidence showed intent to violate Illinois bribery law.
The § 1001 conviction stood because Cui’s recorded FBI interview contained materially false denials about offering business to Burke and about his true motivations.
The district court did not err in § 666 instructions: quid pro quo was sufficiently conveyed without Cui’s proposed “exchange for” wording, and “corruptly” did not require proof Cui knew the conduct was “forbidden.”
Admission of the photoshopped pole-sign photograph was permissible under Rule 404(b) to show motive/intent/state of mind, and any error would be harmless.
The obstruction enhancement under U.S.S.G. § 3C1.1 was supported by Cui’s failure to produce key subpoenaed emails, and the sentencing disparity between Cui and Burke was adequately considered and warranted.

3. Analysis

A. Precedents Cited

1) Re-centering § 666 around bribery after Snyder

The opinion’s interpretive pivot is Snyder v. United States, 603 U.S. 1, 19 (2024), which rejected the Seventh Circuit’s earlier approach that § 666 covered gratuities as well as bribes. The court acknowledges that pre-Snyder Seventh Circuit precedent had “consistently held that § 666 reached gratuities in addition to bribes,” citing United States v. Hawkins, 777 F.3d 880, 881 (7th Cir. 2015). Post-Snyder, the panel treats timing and agreement as central: a bribe involves an up-front payment or an agreement for a future reward tied to a future official act.

2) Quid pro quo and the fate of prior Seventh Circuit “no quid pro quo” language

The court candidly explains that its earlier “no additional, specific quid pro quo requirement” statement in United States v. Agostino, 132 F.3d 1183, 1190 (7th Cir. 1997) and reaffirmed in United States v. Boender, 649 F.3d 650, 655 (7th Cir. 2011) was rooted in the then-prevailing view that § 666 covered gratuities. Because Snyder eliminates gratuities from § 666, that rationale is “undermined,” making it “a fair reading” that § 666 now requires “a corrupt intent to enter a ‘quid pro quo,’” using United States v. Sun-Diamond, 526 U.S. 398, 404-05 (1999) for the classic definition.

Still, the panel holds that quid pro quo need not be expressed in “magic words.” It points to multiple formulations—“in connection with,” “in exchange for,” “in return for,” “for a specific act”—as functionally capable of conveying the requirement, citing, among others, Salinas v. United States, 522 U.S. 52, 55 (1997), United States v. Blagojevich, 794 F.3d 729, 735 (7th Cir. 2015), and United States v. Gee, 432 F.3d 713, 714 (7th Cir. 2005). Notably, the court “encourage[s] the Committee on Pattern Criminal Jury Instructions of the Seventh Circuit to address this issue,” reflecting an institutional recognition that pattern language may need recalibration after Snyder.

3) Agreement and completion of the bribe-giver’s offense

Although the panel declines to resolve whether § 666(a)(2) requires a “preexisting agreement,” it collects authorities emphasizing that the bribe-giver’s crime can be complete upon offering, even if the recipient does nothing: United States v. Whiteagle, 759 F.3d 734, 753 (7th Cir. 2014); United States v. O'Donovan, 126 F.4th 17, 44 (1st Cir. 2025) (quoting United States v. Suhl, 885 F.3d 1106, 1113 (8th Cir. 2018)); United States v. Shen Zhen New World I, LLC, 115 F.4th 1167, 1177 (9th Cir. 2024) (quoting United States v. Rasco, 853 F.2d 501, 505 (7th Cir. 1988)); and United States v. Ring, 706 F.3d 460, 467 (D.C. Cir. 2013).

For what counts as an “agreement,” the court draws from federal bribery doctrine under § 201(b): the agreement “need not be explicit,” citing McDonnell v. United States, 579 U.S. 550, 572 (2016), and reinforcing the point with United States v. Synowiec, 333 F.3d 786, 789 (7th Cir. 2003).

4) “Official act” concepts without adopting an “official act” element

The opinion treats McDonnell v. United States, 579 U.S. 550, 574 (2016) as the relevant source for “official act” framing, while carefully noting that Snyder did not expressly decide whether § 666 includes an “official act” requirement. The panel cites competing signals in other circuits—United States v. Macrina, 109 F.4th 1341, 1351 (11th Cir. 2024) and United States v. O'Donovan, 126 F.4th at 39 n.14. Ultimately, it resolves Cui’s argument by emphasizing § 666(a)(2)’s focus on the bribe-giver’s corrupt intent to influence or reward, not on whether the official successfully performed a qualifying act.

5) Safe harbor under § 666(c) and “bona fide” compensation

On § 666(c), the court anchors the affirmative defense framework in United States v. Lupton, 620 F.3d 790, 802 (7th Cir. 2010) and discusses “ordinary course” compensation via United States v. Robinson, 663 F.3d 265, 272 (7th Cir. 2011). It also cites out-of-circuit interpretations cautioning against laundering bribes as “salary,” including United States v. George, 841 F.3d 55, 62-63 (1st Cir. 2016), United States v. Schmitz, 634 F.3d 1247, 1264 n.13 (11th Cir. 2011) (quoting United States v. Williams, 507 F.3d 905, 908 (5th Cir. 2007)). The key move is doctrinal: where the “legitimate” engagement is the instrument of influence, § 666(c) does not immunize it.

6) Rule 404(b) architecture and Rule 403 balancing

The opinion applies the en banc framework of United States v. Gomez, 763 F.3d 845 (7th Cir. 2014) to uphold admission of the photoshopped photograph for non-propensity purposes (motive, intent, state of mind). It also relies on the direct-vs-other-acts evidentiary distinction discussed in United States v. Han, 105 F.4th 986, 993 (7th Cir. 2024) and United States v. Thomas, 986 F.3d 723, 728 (7th Cir. 2021) (quoting United States v. Gorman, 613 F.3d 711, 717 (7th Cir. 2010)). In assessing the sufficiency of Rule 403 reasoning, the court compares its tolerance for short explanations where context shows real balancing, citing United States v. Adkins, 743 F.3d 176, 184 (7th Cir. 2014).

7) Sentencing: obstruction enhancement and disparity

For the obstruction enhancement, the court cites United States v. Powell, 576 F.3d 482, 498 (7th Cir. 2009) (subpoena noncompliance as obstruction) and defers under the “more than plausible” clear-error standard drawn from United States v. DeLeon, 603 F.3d 397, 404 (7th Cir. 2010). On disparity, it cites the Seventh Circuit’s § 3553(a)(6) approach in United States v. Moore, 50 F.4th 597, 603 (7th Cir. 2022), United States v. Perez, 21 F.4th 490, 491 (7th Cir. 2021), and United States v. Bridgewater, 950 F.3d 928, 936 (7th Cir. 2020).

B. Legal Reasoning

1) The core § 666 holding: quid pro quo exists, but instructions need not say “exchange for”

The court’s most practically important instruction holding is twofold:

Doctrinal clarification: Post-Snyder, § 666 is best understood as requiring bribery (and thus a quid pro quo concept), because gratuities are excluded.
Instructional tolerance: Even so, the pattern “in connection with” language, coupled with “corruptly” and intent-to-influence/reward requirements, can sufficiently communicate quid pro quo—at least where the evidence is not plausibly a gratuity case.

The court fortifies this with a fact-bound rationale: Cui’s own communications (including emails indicating he would offer Burke valuable tax work because Burke was a “powerful broker in City Hall” whose “favor” he needed) allowed the jury to find the requisite exchange relationship without special wording.

2) “Corruptly” as intent to bribe, not knowledge of illegality

Cui sought an instruction adding that corruptly requires “knowledge that giving or offering the thing of value is forbidden.” The court rejects that view: because bribery is “inherently corrupt,” “corruptly” is satisfied when the defendant intends the payment to function as a bribe—i.e., when he expects to achieve “forbidden influence,” relying on Seventh Circuit formulations in United States v. Hawkins, 777 F.3d 880, 882 (7th Cir. 2015), United States v. Mullins, 800 F.3d 866, 870 (7th Cir. 2015), and United States v. Curescu, 674 F.3d 735, 742 (7th Cir. 2012). This is a mens rea choice with meaningful downstream effects: it emphasizes corrupt purpose (bribe-function) rather than requiring proof the defendant also understood the conduct’s legal prohibition.

3) § 666(c) safe harbor cannot sever “legitimate work” from corrupt intent when the work is the bribe

The court treats the property-tax appeal engagement as inseparable from the alleged corrupt exchange. On its analysis, § 666(c) cannot be used to sanitize a transaction merely because it is structured as facially ordinary compensation for real services; if the reason it was offered is to influence official conduct, the “ordinary course” label does not do the work Cui wants. The opinion underscores the evidentiary basis: Cui already had a tax attorney, and his own emails framed Burke’s tax work as the “big bite” to prompt influence on zoning/permitting.

4) Evidence and intent: why the photoshopped image mattered

The panel approves admission of the photoshopped sign photograph because it illustrated Cui’s desperation and willingness to take “shortcuts” to reverse the permit denial—context that made it more likely his outreach to Burke was motivated by the permit crisis and a desire to use influence, not a neutral preference for Burke’s legal skills. That is, the photograph supported a permissible chain of reasoning about motive/intent without relying on “he lies, therefore he bribed.”

5) Sentencing: obstruction and disparity

The obstruction enhancement is sustained on a classic concealment theory: Cui failed to produce two key responsive emails to the government after a grand jury subpoena, and the district court found the omission intentional and material to the investigation. On disparity, the court reiterates that § 3553(a)(6) is not a parity mandate; disparities may be warranted. Here, the district court articulated reasons (including Cui’s obstruction and false statements, and Burke’s age and military service) and imposed a below-guidelines sentence on Cui, supporting substantive reasonableness.

C. Impact

1) Pattern instructions and litigation strategy in § 666 cases post-Snyder

This decision effectively signals a post-Snyder doctrinal recalibration in the Seventh Circuit: § 666 is now treated as a bribery-only statute that conceptually requires quid pro quo, even if the court will not demand any particular talismanic wording in jury instructions. The panel’s express suggestion that the pattern instruction committee “address this issue” foreshadows future instruction reforms—and creates immediate appellate issue-spotting in cases where the evidence could support a gratuity-like narrative.

2) § 666(c) remains narrow where professional services are used as influence currency

The opinion strengthens the government’s ability to prove bribery where the “thing of value” is a legitimate engagement (legal work, consulting, contracts) by refusing to let § 666(c) operate as a form-over-substance defense when the engagement is offered to purchase influence. Defendants will need to meet this by fact development showing genuine need, non-duplicative services, ordinary course selection, and separation from any influence-seeking intent—rather than relying on the engagement’s facial legitimacy.

3) Rule 404(b) in public-corruption trials: “context” evidence survives propensity objections

Public corruption cases frequently turn on intent, and this opinion confirms that courts may admit adjacent conduct (even misconduct) to illuminate motive and state of mind, so long as the government articulates a non-propensity chain of reasoning under United States v. Gomez, 763 F.3d 845 (7th Cir. 2014). The harmless-error backstop further suggests that where there is extensive direct evidence of a corrupt exchange (emails, recorded calls, timing), appellate relief on evidentiary grounds will be difficult.

4) Obstruction enhancements for incomplete productions

The decision underscores the sentencing risk when subpoena responses omit key documents. Even absent proof of destruction, concealment-by-omission can support U.S.S.G. § 3C1.1. Practically, it heightens the importance of defensible collection protocols and careful representations to the government (“no communications are being withheld”) that may later be scrutinized as evidence of intent.

4. Complex Concepts Simplified

Bribe vs. gratuity: A bribe is value offered/accepted to influence a future act; a gratuity is value given after the act as thanks. After Snyder v. United States, 603 U.S. 1, 19 (2024), § 666 criminalizes bribery, not gratuities.
Quid pro quo: Literally “this for that”—an intended trade of something valuable for official influence/action. The court says juries do not need “magic words” so long as the instructions convey the exchange concept.
“Corruptly” under § 666: The court treats this as intending the thing of value to function as a bribe (seeking “forbidden influence”), not necessarily knowing the conduct is unlawful.
§ 666(c) safe harbor: Protects bona fide compensation paid in the ordinary course, but not where the “compensation” is used as the influence mechanism (e.g., steering lucrative work to buy political intervention).
Rule 404(b): Prior/wrong acts can’t be used to show “bad character,” but can be used to show motive, intent, or state of mind. Courts must still weigh unfair prejudice under Rule 403.
Obstruction enhancement (U.S.S.G. § 3C1.1): Can apply if a defendant willfully conceals material evidence during an investigation (including by failing to produce subpoenaed materials).

5. Conclusion

United States v. Charles Cui is a consequential Seventh Circuit application of Snyder v. United States, 603 U.S. 1 (2024). It confirms that § 666 prosecutions must proceed on a bribery (not gratuity) theory and treats a quid pro quo concept as inherent to that bribery framework—yet holds that jury instructions need not use any particular “exchange for” phrasing if the instructions and evidence, taken together, communicate the required corrupt exchange. The court further narrows reliance on § 666(c) where professional engagements are used as the currency of influence, endorses intent-based admission of contextual “other acts” evidence under United States v. Gomez, 763 F.3d 845 (7th Cir. 2014), and reaffirms the sentencing consequences of incomplete subpoena compliance.