The analysis of whether an offense qualifies under these criteria can involve complex questions of state law. In United States v. Manzo, 851 F. Supp. 2d 797, 800 (D.N.J. 2012), the government charged an unsuccessful mayoral candidate with a Travel Act violation for accepting a campaign contribution in exchange for a promise to assist the development of real estate interests held by the bribe payor if the candidate prevailed in the election. The court, after extensively reviewing New Jersey’s bribery and solicitation statutes, as well as the common law of bribery, determined that neither specifically proscribed the acceptance of a benefit by an unsuccessful candidate in exchange for a promise to perform an official act once elected. Id. at 811–29. Therefore, the government had not properly alleged a Travel Act violation, and the court granted the defendant’s motion to dismiss the indictment. Id. at 829. The court did, however, note that “it is a crime in New Jersey to engage in bribery as a candidate in order to purchase or induce certain behaviors of voters specifically,” id. at 812, indicating that a vote-buying allegation would constitute a valid charge under the Travel Act. Travel Act jurisdiction rests on predicate acts of interstate travel, the use of interstate facilities, or the use of the mails (intra or interstate). E.g., United States v. Nader, 542 F.3d 713, 722 (9th Cir. 2008) (“We hold that intrastate telephone calls made with intent to further unlawful activity can violate the Travel Act because the telephone is a facility in interstate commerce.”); United States v. Halloran, 821 F.3d 321, 342 (2d Cir. 2016), cert. denied, 137 S. Ct. 1118 (2017) (citing Nader, 542 F.32 at 722) (holding purely intrastate use of an interstate facility, “e.g., the telephone or the internet” is sufficient to violate the Travel Act). Since election fraud is a local crime, interstate predicate acts are rarely present. The Travel Act m a y be considered as a vehicle to prosecute vote-buying schemes, however, in which the mails, a telephone, or the internet were used in those states where vote-buying is statutorily defined as bribery. This theory is one of the few available that do not require a federal candidate on the ballot. 65