United States v. Shynita Townsend, 630 F.3d 1003

Febles, a drug offender released on $500,000 bond with home confinement and a tracking ankle bracelet, was supervised by Townsend, a Miami-Dade corrections officer.
Febles bought himself greater freedom by giving Townsend a $280 pair of diamond earrings and $5,000 in cash to extend release privileges and evade monitoring.
Townsend falsified or back-dated a travel authorization letter and created excuses to cover Febles’absences; she also accepted and concealed bribe-related benefits.
Febles was later arrested for trafficking-related offenses; Townsend’s conduct prompted a federal investigation and led to charges under 18 U.S.C. § 666(a)(1)(B) and related obstruction and accessory offenses.
A jury convicted Townsend of bribery (count 1) and four obstruction/related counts, and the district court sentenced her to concurrent terms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether intangibles can be a “thing of value” under §666(a)(1)(B).	Intangibles (freedom, increased release) meet the term “thing of value.”	Intangibles cannot be the value supporting §666(a)(1)(B).	Yes; intangibles are things of value.
How to value intangible benefits to meet the $5,000 threshold.	Use market value; bribe amount proxies value of the intangible.	Value cannot be reliably measured; threshold cannot be satisfied.	Adopt market-value approach; total bribe value ($5,280) satisfies the threshold.
Sufficiency of evidence for Townsend’s bribery conviction.	Evidence shows Townsend accepted and intended to be rewarded for aiding Febles.	Evidence insufficient to prove value or intent beyond reasonable doubt.	Sufficient evidence supports bribery conviction.
Sufficiency of evidence for Townsend as an accessory after the fact.	Townsend knew of Febles’ offense and assisted him to avoid punishment.	No clear proof she aided avoidance of apprehension.	Sufficient evidence to convict on accessory after the fact.
Sufficiency of evidence for obstruction of justice (Count 3 and Count 4).	Tampering with or concealing Febles’ file and warning calls impeded official proceedings.	Entries in copies and timing unclear; warnings insufficient.	Convictions affirmed; evidence supported both obstruction theories.

United States v. Marmolejo, 89 F.3d 1185 (5th Cir. 1996) (market-value approach to intangible benefits in §666(a)(1)(B))
United States v. Fernandes, 272 F.3d 938 (7th Cir. 2001) (expungement/bribery value exceeding threshold)
United States v. Zimmermann, 509 F.3d 920 (8th Cir. 2007) (amount of bribe sufficient for threshold; value of intangibles)
United States v. Hines, 541 F.3d 833 (8th Cir. 2008) (intangibles as things of value under §666(a)(1)(B))
United States v. Nilsen, 967 F.2d 539 (11th Cir. 1992) (‘thing of value’ includes intangible objectives)
United States v. Moore, 525 F.3d 1033 (11th Cir. 2008) (broadly inclusive of intangibles under ‘thing of value’)
Sabri v. United States, 541 U.S. 600 (2004) (recognizes broad reach of federal gratuities statute context)