Second Circuit: United States v. Calk

 Bank officer's approval of loans in hopes of a Presidential appointment was illegal, as, for purposes of the statute, corrupt conduct need only be motivated at least in part by improper motives, and commercial decisions that might offer legitimate benefits are not insulated from the inquiry.  The thing of value at issue need not have pecuniary value. The value of the intangible thing at issue can be determined to exceed the statutory minimum by establishing its value to the deft.

The grand jury subpoena of a third party wasn't improper; although the suspicious timing was enough to shift the burden, the subsequent superseding indictment, among other things, established its legitimacy.

United States v. Calk