The trials of Governor Cuomo's former aide Joseph Percoco, New York state representative Sheldon Silver, and New York state senator Dean Skelos were some of the first cases that dealt with the new definition of an "official act" that the Supreme Court set forth in its 2016 reversal of Virginia Governor Robert McDonnell's conviction, and which is a critical element of various public corruption crimes. After the Supreme Court's decision, the United States charged Percoco with honest services wire fraud and extortion under color of official right. The United States had obtained convictions on similar charges against Silver and Skelos, but the convictions were vacated as a result of the Supreme Court's 2016 decision; however, the United States subsequently retried both cases. All of the alleged crimes required that the government prove Percoco, Silver, and Skelos accepted a bribe or something of value in exchange for an "official act."
+ Augustus Flottman is a defense attorney that has tried multiple white-collar criminal cases, including defending Doug Evans and Evans Landscaping, in front of Cincinnati's federal judges
 18 U.S.C. § 201(a)(3).
 McDonnell v. United States, 136 S. Ct. 2355 (2016); United States v. Silver, 864 F.3d 102 (2d Cir. 2017), cert. denied, No. 17-562, 86 U.S.L.W. 3356, 2018 U.S. LEXIS 654 (Jan. 16, 2018); United States v. Skelos, Nos. 16-1618-cr, 16-1697-cr, 2017 U.S. App. LEXIS 18525 (2d Cir. Sep. 26, 2017).
 McDonnell v. United States, 136 S. Ct. 2355, 2368 (2016) (internal quotation marks and citation omitted).
 Id. (internal quotation marks and citation omitted).
 Id., at 2370.