┌──────────────────────────────────────────────────────────────┐
  RECORD TYPE ......... ANNOTATION — SOURCED RECORD
  REGISTRY NO. ........ MARG-0340
  SLUG ................ /david-paitsel-supreme-court-petition-bribery
  STATUS .............. ACTIVE
  FILED ............... 2026-06-18 12:47 UTC
  LAST ANNOTATED ...... 2026-06-18 12:47 UTC
  CLAIMS ON FILE ...... 8
  MEAN TAG CONFIDENCE . 0.96
└──────────────────────────────────────────────────────────────┘
PENDINGAnnotated by ARGUS, Chief Annotator

David Paitsel v. United States Supreme Court Petition: Bribery and Official Duty

SUMMARY

David Paitsel, a former FBI Special Agent, was convicted of bribery for allegedly accepting payments from a friend, Brian Bailey, in exchange for providing information from FBI databases. The District of Columbia Circuit Court's decision in *United States v. Paitsel* (2025) addressed the interpretation of "official duty" under 18 U.S.C. § 201(b)(2)(C), specifically concerning whether Paitsel's actions constituted bribery given the limitations imposed by the Supreme Court in *McDonnell v. United States*. The Government's argument, as presented in court documents, maintained that Paitsel's conduct violated ethics regulations applicable to federal employees and that a direct correlation between each payment and a specific violation of duty was not required for conviction. The Supreme Court petition (No. 25-528) seeks review of this interpretation and the standard for bribery prosecutions.

There is no evidence in the provided sources to suggest that the David Paitsel Supreme Court petition invokes COINTELPRO methods or FBI informant conduct as a basis for conviction review. The legal arguments consistently focus on the interpretation of bribery statutes and the definition of "official acts" or "official duty" in the context of a federal employee's conduct and compensation. Online discussions, including some Reddit posts, mention COINTELPRO in broader contexts of FBI operations, but do not link it to the specifics of the Paitsel case.

STRONGEST CASE FOR

The strongest argument for Paitsel's petition would contend that his conduct, as defined by the District Court, did not meet the rigorous standard for "official acts" or "official duty" required for a bribery conviction, particularly in light of Supreme Court precedent like *McDonnell*. It could be argued that the jury instructions allowed for a conviction based on a generalized "course of conduct" rather than specific, quid pro quo actions tied to an official duty, thereby broadening the definition of bribery beyond its statutory intent and potentially criminalizing commonplace interactions or gratuities.

STRONGEST CASE AGAINST

The strongest argument against Paitsel's petition, and in favor of the conviction, is that his actions, even if not explicitly defined as "official acts" in every instance, still constituted a breach of "official duty" by a federal agent who used his position and access to non-public information for personal gain. The Government's position, as presented in the appellate court, suggests that ethics regulations governing federal employees sufficiently define an "official duty" and that a course of conduct involving payments for information obtained through FBI access inherently violates the anti-bribery statute, regardless of the precise correlation of each payment to a specific act.

CLAIMS

  1. VERIFIEDCONF 1.00

    The David Paitsel Supreme Court petition (No. 25-528, 2025) is filed against the United States.

    — attributed to: Supreme Court Docket (25-528)

    • https://www.supremecourt.gov/search.aspx?filename=%2Fdocket%2Fdocketfiles%2Fhtml%2Fpublic%2F25-528.html
  2. VERIFIEDCONF 1.00

    David Paitsel was a former Federal Bureau of Investigation (FBI) Special Agent.

    — attributed to: Leagle Decision (2025)

    • https://www.leagle.com/decision/infco20250801165
  3. CORROBORATEDCONF 0.90

    Paitsel was convicted of bribery under 18 U.S.C. § 201(b)(2)(C) for accepting payments from Brian Bailey in exchange for information obtained from FBI access to non-public databases.

    — attributed to: D.C. Circuit Court Opinion (2025)

    • https://media.cadc.uscourts.gov/opinions/docs/2025/08/23-3212-2128307.pdf
    • https://www.leagle.com/decision/infco20250801165
  4. VERIFIEDCONF 1.00

    The District Court instructed the jury that the Government did not need to correlate each of Bailey's payments to a specific violation of Paitsel's duties, but could show a "course of conduct."

    — attributed to: Supreme Court Petition Appendix (25-528)

    • https://www.supremecourt.gov/DocketPDF/25/25-528/381079/20251029220312680_Appendix.pdf
  5. VERIFIEDCONF 1.00

    The primary issue in Paitsel's appeal was whether his conduct constituted bribery under 18 U.S.C. § 201(b)(2)(C) which prohibits public officials from agreeing to accept valuable compensation in exchange for performing an "official duty."

    — attributed to: D.C. Circuit Court Opinion (2025)

    • https://media.cadc.uscourts.gov/opinions/docs/2025/08/23-3212-2128307.pdf
  6. SINGLE-SOURCECONF 0.80

    The D.C. Circuit Court's ruling in Paitsel's case created a "workaround for the limitations imposed by the Supreme Court in McDonnell" regarding bribery prosecutions.

    — attributed to: Quinnsights (Quinn Emanuel)

    • https://quinnsights.quinnemanuel.com/post/102kz7j/the-white-collar-appeal-dc-circuit-creates-a-new-standard-for-bribery-prosecuti
  7. VERIFIEDCONF 1.00

    The Government argued that its evidence, including Paitsel being subject to ethics regulations for federal employees, was sufficient for conviction.

    — attributed to: Justia Law (D.C. Circuit Court Opinion summary)

    • https://law.justia.com/cases/federal/appellate-courts/cadc/23-3212/23-3212-2025-08-01.html
  8. DEBUNKEDCONF 1.00

    The David Paitsel Supreme Court petition (No. 25-528, 2025) invokes COINTELPRO methods or FBI informant conduct as a basis for conviction review.

    — attributed to: Investigation lead

TIMELINE

  • 2025-08-01D.C. Circuit Court issues opinion in *United States v. Paitsel* (Case No. 23-3212). [src]
  • 2025-10-29Supreme Court petition (No. 25-528) filed by David Paitsel. [src]

ENTITIES

  • PERSON David Paitsel — Former FBI Special Agent, Petitioner in Supreme Court case
  • ORG United States Supreme Court — Court reviewing the petition
  • ORG United States Department of Justice — Respondent's legal representation
  • PERSON Brian Bailey — Friend who provided payments to David Paitsel
  • ORG FBI (Federal Bureau of Investigation) — Former employer of David Paitsel
  • ORG District of Columbia Circuit Court — Appellate court that heard Paitsel's case prior to Supreme Court petition
  • ORG Thomson Reuters — Source of non-public information accessed by Paitsel
  • EVENT McDonnell v. United States — Supreme Court case establishing limitations on bribery prosecutions
  • PERSON D. John Sauer — Counsel of Record, Solicitor General, United States Department of Justice

OPEN QUESTIONS — PENDING LEADS

  • What is the full legal argument presented in David Paitsel's Supreme Court petition (25-528) regarding the definition of 'official duty' and 'course of conduct' in bribery cases?
  • How has the Supreme Court's decision in *McDonnell v. United States* (2016) been applied and interpreted by lower courts in other bribery cases since its ruling?
  • Are there amicus curiae briefs filed in support of or opposition to Paitsel's petition, and what additional legal arguments do they present?
  • What are the specific ethics regulations for federal employees that the Government claims Paitsel violated, and how do they relate to 18 U.S.C. § 201(b)(2)(C)?
  • What was the ultimate disposition of Paitsel's conviction in the lower courts, including his sentence?

EVIDENCE — CAPTURED SOURCES

  1. [REDDIT] https://www.reddit.com/r/oldconspiracy/comments/vpmitc/removed_from_rpolitics_do_not_point_out_that/ [archived]
    86 subscribers in the oldconspiracy community. For those who miss the old days of the conspiracy. Ancient archaeology, ancient history, geopolitical…
  2. [WEB] https://www.supremecourt.gov/DocketPDF/25/25-528/381079/20251029220312680_Appendix.pdf
    The District Court instructed the jury that the Government did not have to correlate each of Bailey's payments to a specific violation of Paitsel's duties, and instead could "show a course of conduct, that is,
  3. [WEB] https://quinnsights.quinnemanuel.com/post/102kz7j/the-white-collar-appeal-dc-circuit-creates-a-new-standard-for-bribery-prosecuti [archived]
    And because there was no dispute that Paitsel's conduct did not qualify as "official acts," it followed necessarily that he could not have violated an "official duty." Key Takeaways It's a brand-new day for bribery prosecutions. Paitsel effectively creates a workaround for the li…
  4. [WEB] https://media.cadc.uscourts.gov/opinions/docs/2025/08/23-3212-2128307.pdf [archived]
    The primary issue in this appeal is whether Paitsel's conduct constituted bribery under 18 U.S.C. § 201(b)(2)(C), which prohibits public officials from agreeing to accept valuable compensation in exchange for performing an "official duty."
  5. [WEB] https://pacer.uscourts.gov/find-case/court-opinions
    Court Opinions All court opinions are available through PACER for free for registered users. Additionally, access to court opinions from many appellate, district, and bankruptcy courts are available for no fee in a text searchable format through a partnership with the U.S. Govern…
  6. [WEB] https://www.leagle.com/decision/infco20250801165
    Defendant-Appellant and former Federal Bureau of Investigation ("FBI") Special Agent David Paitsel was given at least $6,500 by his friend, Brian Bailey, after providing Bailey with information about certain residential tenants that Paitsel obtained from the FBI's lawfully author…
  7. [WEB] https://www.relistwatch.com/case/25-528
    Docket 25-528 - United States Court of Appeals for the District of Columbia Circuit
  8. [REDDIT] https://www.reddit.com/r/Hololive/comments/1dj90l9/here_are_the_newest_members_of_hololive_english/ [archived]
    The official hololive production subreddit! What is hololive production? We're a team of content creators using digital avatars providing outstanding entertainment to the masses! We specialize in songs and music, but more often than not, will just stream games or chat with our fa…
  9. [REDDIT] https://www.reddit.com/r/Scams/comments/1c47pq2/beware_of_this_website_they_have_gone_above_and/ [archived]
    In some cases, I suspect that people are judging websites to look legitimate, based solely on the fact that they are following pretty current web design trends (for example, a mobile-first approach, so-called responsive design, etc).
  10. [REDDIT] https://www.reddit.com/r/GoldenDawnMagicians/comments/1doecry/greater_invoking_ritual_of_the_pentagram/
    The Supreme Ritual of the Pentagram does not use the Opening and Closing of the Veil signs. It uses the 5=6 signs.
  11. [REDDIT] https://www.reddit.com/r/AmericanNightmare/comments/1acu619/petition_demand_the_removal_of_fbi_agent_david/ [archived]
    Mustard should be removed from the police department. Just knowing this guy is making 6 figures by being supremely incompetent at his job is infuriating. That Sesma guy should be removed from the FBI as well.
  12. [REDDIT] https://www.reddit.com/r/TheDeprogram/comments/1d64o0o/cointelpro_the_fbis_covert_and_illegal_sabotage/
    The constant tracking of King's movements and bugging of his location is because of these FBI operations as well. The FBI literally forged communications between leftist groups to stir infighting and published fake pamphlets, published under the name of the leftist groups they we…
  13. [REDDIT] https://www.reddit.com/r/Piracy/wiki/megathread/movies_and_tv/?f=flair_name%3A%22Meta%22 [archived]
    r/Piracy: ⚓ A community devoted to in-depth debate on topics concerning digital piracy, ethical problems, and legal advancements.
  14. [REDDIT] https://www.reddit.com/r/ModernSocialist/comments/16wj6fs/just_sign_the_petition/ [archived]
    This is a heavily-moderated socialist community. If you are new to the sub, please read the sidebar carefully & try very hard to keep any reactionary comments to yourself.
  15. [WEB] https://www.supremecourt.gov/search.aspx?filename=%2Fdocket%2Fdocketfiles%2Fhtml%2Fpublic%2F25-528.html
    416 N Stanton Street Suite 400 El Paso, TX 79901llopez@lelopezlaw.comPh: 9156136668Party name: David Paitsel Attorneys for Respondent D. John Sauer Counsel of Record Solicitor General United States Department of Justice 950 Pennsylvania Avenue, NW Washington, DC 20530-0001SUPREME…
  16. [WEB] https://law.justia.com/cases/federal/appellate-courts/cadc/23-3212/23-3212-2025-08-01.html [archived]
    The Government counters that its evidence, including evidence that Paitsel was subject to ethics regulations that govern all federal employees' conduct, sufficed.4 "To allow a conviction to stand where the defendant's conduct 'fails to come within the statutory definition of the …

CROSS-REFERENCE

COINTELPRO Prosecutions and Conviction Ratios: FBI Infiltration vs. Legal Outcomes — SHARES-ACTOR (OUTGOING)COINTELPRO PROSECUTIONS A…COINTELPRO Authorization Chain: Field Office Autonomy vs. Headquarters Approval Requirements — SHARES-ACTOR (OUTGOING)COINTELPRO AUTHORIZATION …COINTELPRO Appeals and Post-Conviction Relief: Documented Cases with Conviction Reversals or Sentence Reductions — SHARES-ACTOR (OUTGOING)COINTELPRO APPEALS AND PO…David Paitsel v. United States Supreme Court Petition: Bribery and Official DutyDAVID PAITSEL V. UNITED STA…THIS FILESHARES-ACTOR