In this article, Tim O'Toole comments on the recently filed petition for certiorari with the Supreme Court to overturn Kevin Ring's 2010 conviction on corruption charges. One of the questions posed to the Supreme Court is can a honest-services fraud conviction stand without proof of a quid pro quo bribery agreement. The appellate court ruled that no such proof is required. O'Toole said in the petition that the DC Circuit "permitted the expansion of honest-services fraud" beyond what's permissible.