Earlier this week, the Southern District of New York dismissed bribery and honest services wire fraud charges brought against New York’s former lieutenant governor, Brian Benjamin, based upon the Indictment’s failure to allege an explicit quid pro quo arrangement with respect to campaign contributions, instead of an agreement by implication. The decision marks the first time that a New York federal court has held that an express agreement is required before an individual can be convicted of bribery and wire fraud in a campaign contribution case,… More