This article discusses two additional issues the McDonnell case raises. The first issue is how much evidence is necessary to sustain a conviction for attempting to obstruct an official proceeding. Mrs. McDonnell was convicted of attempting to obstruct the grand jury in this case for sending a misleading note to Williams, but her actions were deemed insufficient to support her obstruction conviction. The other issue relates to the McDonnells' sentencing. The sentences they received were much shorter than the sentences calculated using the United States Sentencing Guidelines. This article considers the official act issue, the obstruction issue, and the sentencing issue. Part I describes the relationship between the McDonnells and Williams. Part II discusses what official acts a public official must take to be guilty under the public corruption statutes the McDonnells were convicted of violating. Part III discusses Mrs. McDonnell's obstruction charge. Part IV discusses issues surrounding the McDonnells' sentencing.
Henry L. Chambers, Jr., The McDonnell Case: A Clarification of Corruption Law or a Confusing Application of Corruption Law, 50 U. Rich. L. Rev. 237 (2015).