confidential relationships to senior public officers, when partisan loyalty is a reasonably necessary element of the job. Id. The distinction between ministerial public positions and those that involve policy formulation is difficult, and has, in the past, been left by the courts largely to a case-by-case analysis. Nevertheless, the distinction is important in assessing the scope and purpose of federal criminal laws addressing illegal patronage. STATUTES The text of the criminal statutes discussed in this section is printed in Appendix B. Each of these statutes carries, in addition to the prison term noted, fines under 18 U.S.C. § 3571. 1. Limitations Based on Federal Employment or Workspace (a) Solicitation of political contributions: 18 U.S.C. § 602 Section 602 prohibits a United States Senator or Representative, a candidate for Congress, officer or employee of the United States, or person receiving compensation for services from the United States Treasury, from knowingly soliciting any contribution from any other such officer, employee, or person, except as permitted under the 1993 Hatch Act amendments. The statute applies only to contributions made to influence a federal election. Violations are punishable by imprisonment for up to three years. Section 602 has been interpreted by the courts as criminalizing aggravated forms of political “shakedowns.” United States v. Wurzbach, 280 U.S. 396, 398 (1930) (statute prohibits exerting “pressure for money for political purpose”); Ex parte Curtis,106 U.S. 371, 374 (1882) (statute protects federal employees against political “extractions through fear of personal loss”); see also Brehm v. United States, 196 F.2d 769, 770 (D.C. Cir. 1952); United States v. Burleson, 127 F. Supp. 400, 402 (E.D. Tenn. 1954). 101