Page:Impeachment of Donald J. Trump, President of the United States — Report of the Committee on the Judiciary, House of Representatives.pdf/126

 undue Reward," "valuable thing," or valuable consideration, even where "the things were small." The value of the thing was measured by its value to the public official who was offering, soliciting or receiving it. Accordingly, as Professor Turley recognized in his testimony, the common law encompassed non-pecuniary things of value—even including, in the case of King Charles II (as would have been well known to the Framers), "a young French mistress." Consistent with this broad understanding, in guarding against foreign efforts to corrupt American officials, the Constitution forbids any "Person holding any Office of Profit or Trust," from accepting "any present, Office or Title, of any kind whatever, from. . . a foreign State," unless Congress consents. An equally capacious view applies to the impeachable offense of "Bribery."

Applying the constitutional definition of "Bribery" here, there can be little doubt that it is satisfied. President Trump solicited President Zelensky for a "favor" of great personal value to him he did so corruptly. and he did so in a scheme to influence his own official actions respecting the release of military and security assistance and the offer of a White House meeting.

b.Criminal Bribery, 18 U.S.C. § 201

Although President Trump's actions need not rise to the level of a criminal violation to justify impeachment, his conduct here was criminal. In this section we address the federal statute banning bribery; in the next section we address the wire fraud statute. Both of these laws underscore the extent to which Congress and the American people have broadly condemned the use of a public position of trust for personal gain. As this Committee observed decades ago, "[n]othing is more corrosive to the fabric of good government than bribery." Bribery, Graft, and Conflicts of Interest, H. Rep. No. 87-748, at 6 (1961).</ref. The federal anti-bribery statute imposes up to fifteen years'