The First Amendment protects soliciting for, and contributing to, political campaigns based on policies that a candidate agrees to take while in office. To avoid chilling that core speech, this Court's precedent requires an explicit quid pro quo when the alleged "bribe" is a contribution. Yet some courts, invoking Evans v. United States, allow conviction on ambiguous "in return for" evidence and "as opportunities arise" jury instructions.

When alleged bribery rests solely on lawful campaign contributions, must the government prove an explicit, unambiguous quid pro quo conditioning an official act, or may a conviction rest on such ambiguity?

When alleged bribery rests solely on lawful campaign contributions, must the government prove an explicit, unambiguous quid pro quo conditioning an official act, or may a conviction rest on such ambiguity?