In 2016, the Supreme Court granted certiorari to former Governor Bob McDonnell’s public corruption case. In 2014, a federal jury found McDonnell guilty of eleven counts of public corruption for accepting over $175,000 worth of gifts and loans from Virginia businessman Jonnie Williams. The conviction was affirmed by the Fourth Circuit. In overturning the Fourth Circuit, the Supreme Court significantly narrowed the definition of an “official act” in the federal bribery statute, which is the controlling statute in most public corruption cases. This Comment argues that the Court’s decision unduly narrows the bribery statute’s scope to punish only the most egregious acts of public corruption. This Comment suggests drawing upon a hybrid between the agency and corporate duties of loyalty in private law to amend the federal bribery statute and provide a more practicable standard by which courts can distinguish between regular constituent services and unlawful public corruption.