Republican Party of Illinois, 497 U.S. 62 (1990) (patronage promotions and hirings of rank-and-file public employees violate rights of speech and association); Branti v. Finkel, 445 U.S. 507, 517–19 (1980) (public employees may not be discharged based solely on their political beliefs unless party affiliation is an appropriate requirement for effective performance); Elrod v. Burns, 427 U.S. 347, 367 (1976) (patronage dismissals of non-policymaking public employees violate the First and Fourteenth Amendments). Although Sections 600 and 601 are misdemeanors, there are alternative felony theories of prosecution that may be applicable to conduct implicating these statutes. Such theories include: • The Travel Act, 18 U.S.C. § 1952, in states having statutes that broadly define bribery and extortion. • Conspiracy to defraud the United States, 18 U.S.C. § 371, to the extent that the evidence shows a conspiracy to defraud the public of the fair and impartial administration of a federal grant or program. • Bribery concerning federally funded programs, 18 U.S.C. § 666. However, the Third Circuit has held Section 666 inapplicable to a scheme to demand non-pecuniary political services from public employees. See United States v. Cicco, 938 F.2d 441, 444–46 (3d Cir. 1991). The Cicco case illustrates the use of alternative theories to prosecute local public officials for corrupt patronage abuses. Unfortunately, the case also illustrates the difficulties involved in prosecuting patronage crimes under current law. Although the jury convicted the defendants under both Section 601 and Section 666, the two convictions were ultimately reversed on appeal. In Cicco, local public officials demanded political services from part-time public employees, and when the employees refused to perform the services, the employees were denied permanent 109