United States v. Oaks

Additional considerations cement the instant allegations within the range of conduct proscribed by federal law after McDonnell . Drafting legislation lies at the very heart of a legislator's official purpose. A draft bill is therefore distinct from other conduct based merely on a legislator's privileged access or administrative perqs, which alone do not make conduct "official" under 18 U.S.C. § 201(a)(3). See McDonnell , 136 S.Ct. at 2368 ; United States v. Silver , 864 F.3d 102, 120 (2d Cir. 2017) (use of official letterhead insufficient under McDonnell ); Valdes, 475 F.3d at 1329-30. This…