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U.S. v. Pratt, No. ELH-12-401, 2013 WL 310565 (D. Md. Jan. 24, 2013)

January 24, 2013

The defendant was charged with receipt of illegal supplementation of salary from a non-governmental source in violation of 18 U.S.C. § 209(a). Denying the defendant’s motion to dismiss, the District Court of Maryland rejected the defendant’s argument that services, such as spa and salon services, could never constitute supplementation of salary. In its opinion, the court discusses the legislative history of 18 U.S.C. § 209(a) and case law interpreting the statute.

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