Defendant was convicted in the Court of Common Pleas of three counts of bribery in official and political matters. Defendant appealed.
The Supreme Court of Pennsylvania held that:
- Evidence was sufficient to support conviction for bribery in official and political matters;
- The trial court erred when it failed to instruct the jury that the default culpability requirement of reckless conduct applied to offense of bribery in official and political matters; and
- The error was harmless.
Defendant, a publicly elected official, stated to purchaser, who was purchasing land from town, that zoning approval could be expedited if purchaser paid an additional $500,000, the bribery statute did not require defendant to act with a corrupt motive, and it did not require that defendant solicit a benefit for himself, rather, benefit was defined to include situations where a public servant solicited money, gain, or an advantage for any other person or entity in whose welfare the servant was interested, and defendant sought to provide a benefit to town.