The U.S. Supreme Court cleared the way for a former Cincinnati City Council member convicted of bribery and attempted extortion but later pardoned by President Donald Trump to have those charges dismissed in the lower courts.
The ruling came as the high court has, in recent years, been willing to overturn corruption convictions involving public officials engaging in activities some consider normal political activity. For example, in 2016, the Supreme Court vacated the conviction of the former Republican governor of Virginia, Bob McDonnell, for accepting gifts from a benefactor without actually taking action to benefit that person.
On April 6, the justices granted Alexander “P.G.” Sittenfeld’s petition in an unsigned order. The court did not explain its decision. No justices dissented. The court disposed of the case summarily without hearing oral arguments.
The Supreme Court also vacated the convictions and sent the case back to the U.S. Court of Appeals for the Sixth Circuit to be reconsidered in light of a pending motion to dismiss the indictment against Sittenfeld.
The new ruling came after Trump pardoned Sittenfeld on May 28, 2025. This act of presidential clemency eliminated his 16-month sentence of incarceration after he had served almost five months of it.
A presidential pardon forgives federal criminal offenses and removes the legal consequences of those offenses, but does not change history by erasing the judicial finding of guilt.
The pardon covered Sittenfeld’s October 2023 conviction for bribery and attempted extortion related to an FBI-led sting operation that involved campaign contributions. Prosecutors said he accepted $20,000 in donations to his political action committee from undercover FBI agents who feigned interest in developing a specific property. Prosecutors also said Sittenfeld’s actions went beyond mere campaign fundraising to bribery that constituted an illegal quid pro quo for backing the development project.
A quid pro quo—from Latin, meaning “this for that”—is something given or received in exchange for something else.
Sittenfeld’s attorney said in the petition that he was considered “a rising star in Ohio politics,” first elected to the Cincinnati City Council in 2011 at age 27, making him the youngest person ever elected to the council.
“A defining trait of Sittenfeld’s political identity was his unwavering support for economic development. He voted for every economic development deal put in front of him while on the Council,” according to the petition.
In 2018, Sittenfeld approached a local developer to help raise money for his mayoral campaign, in order to match contributions from other developers, and “nothing about this was unlawful,” the petition said.
The government was informed about this, and the FBI organized a sting operation. The local developer contacted Sittenfeld about a specific project, which the then-elected official was already supporting, and offered to connect him with potential investors, who were actually undercover agents. The agents proposed a quid pro quo, saying if Sittenfeld agreed to back the project, they would donate to his campaign, the petition said.
The petition said Sittenfeld filed a motion after the conviction for post-trial relief, saying the evidence at trial was not sufficient to prove an “explicit” quid pro quo, as required by McCormick v. United States (1991). In that case, the Supreme Court ruled that the receipt of a campaign contribution was not a federal crime unless the payment was part of an “explicit quid pro.”
The federal district court ruled that the evidence was “ambiguous” at best and believed that, despite that, the jury could still surmise an “explicit” exchange from the record. The court sentenced Sittenfeld to 16 months and fined him $40,000. A divided panel of the Sixth Circuit upheld the conviction, finding the jury was allowed to conclude based on the ambiguous evidence that he had accepted an illegal bribe.
In the petition, Sittenfeld’s attorney urged the Supreme Court to take up the case, saying candidates “routinely raise money based on pledges of official action: ‘Donate to me and I will vote to repeal the law my opponent supported!’ ‘Send me a campaign check and I will cut your taxes—I can’t do it without you!’”
Hellbound and Down 