United States v. Inzunza, 638 F.3d 1006

San Diego No-Touch ordinance banning touching between exotic dancers and patrons prompted efforts to repeal the law by city officials and Galardi associates.
Galardi funded political influence via Malone and D'Intino, contributing to Inzunza's campaign and signaling potential repeal support in exchange for actions against the ordinance.
Malone and Inzunza discussed covert plans including leveraging a police officer to provide cover for repeal efforts and sending emails to council members to frame the matter.
Zucchet received large campaign contributions but initially returned them due to reputational risk; later plans involved more covert cash payments for influence.
A series of meetings and phone conversations from 2002–2003 tied contributions to anticipated official actions to repeal or modify the No-Touch ordinance, culminating in referrals to the City Council committee.
In May 2003 government raids and indictments followed; both Inzunza and Zucchet were convicted of various counts of honest services fraud, conspiracy, and Hobbs Act extortion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for quid pro quo	Inzunza's convictions supported by explicit promises tied to contributions.	Evidence relies on co-conspirator statements; not enough direct quid pro quo.	Quid pro quo supported; sufficient evidence for conviction.
Indictment sufficiency and elements	Indictment properly alleged material acts and intents; state-law violation not required.	Indictment missing implied elements (private gain, state-law violation, materiality).	Indictment sufficient; private gain not an element; state-law violation not required; materiality adequately alleged.
Good faith instruction	Failure to give good faith instruction was error.	No need for good faith instruction due to specific intent requirement.	No error; jury instruction on specific intent sufficed.
Brady and closing argument misconduct	Brady violations and improper closing arguments denied due process.	Any Brady material was immaterial; closing remarks were permissible.	No reversible Brady error; any closing-argument issues harmless.

McCormick v. United States, 500 U.S. 257 (U.S. 1991) (explicitness required for quid pro quo in extortion cases)
Carpenter v. United States, 961 F.2d 824 (9th Cir. 1992) (circumstantial evidence and context used to prove quid pro quo)
DuBois v. United States, 186 F.3d 1179 (9th Cir. 1999) (implied elements for honest services fraud; private gain not required)
Weyhrauch, 548 F.3d 1237 (9th Cir. 2008) (holding on state-law violation requirement for honest services fraud; cert. granted)
Griffin v. California, 380 U.S. 609 (U.S. 1965) (prohibition on commenting on defendant’s failure to testify)