In the course of representing Searby PLLC’s client, D.C. Councilmember Trayon White (Ward 8), at trial last month, a positive development for federal birbery law came about from our motion practice. In a pre-trial order on September 5th, 2026, Judge Contreras granted our motion in limine to limit the government’s use of violations of the D.C. Council’s Code of Conduct as evidence of a “quo” in quid pro quo. Judge Contreras agreed with us that violating local ethics provisions simply by accepting a gift does not itself satisfy the quid pro quo requirement in the federal bribery statute. Judge Contreras criticized the government’s novel legal theories for their “circularity” and “vagueness.” His opinion can be read in its entirety on Westlaw and is attached below.