Sauer reported in that prospective case, it "might be an Formal act" that will have to have impeachment and conviction before He's prosecuted. All those examples, he wrote, propose that “gratuities following the Formal act are not similar to bribes ahead of the official act,” including that compared with gratuities, https://econopass.com/news/world/supreme-court-ruling-is-bad-news-for-america/